ML20132F600

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Responds to NRC Re Violations Noted in Insp Repts 50-317/96-07 & 50-318/96-07.Corrective Actions:All Packages & Containers of Radioactive Material Will Be Inspected Prior to Shipment
ML20132F600
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 12/17/1996
From: Cruse C
BALTIMORE GAS & ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9612260032
Download: ML20132F600 (3)


Text

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l CucLF.s II. Cr_Uht:

Haltimore Gas and Electric Company Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455 December 17,1996 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Reply to Notice of Violation NRC Region i Inspection Report Nos. 50-317(318V96-07

REFERENCE:

(a)

Letter from L. T. Doerflein (NRC) to C.11. Cruse (BGE), dated November 19, 1996, NRC Region i Integrated Inspection Report Nos.

50-317/96-07 and 50-313/96-07 and Notice of Violation In response to Reference (a), Attachment (1) is provided.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, 7

'/'

/

w CliC/RCG/bjd j

Attachment cc:

D. A. Brune, Esquire

11. J. Miller, NRC J. E. Silberg, Esquire Resident inspector, NRC

/

Director, Project Directorate I-1, NRC R.1. McLean, DNR A. W. Dromerick, NRC J. II. Walter, PSC

\\ h 9612260032 961217

{DR ADOCK 05000317 PDR

i ATTACHMENT (1)

REPLY TO NOTICE OF VIOLATION NOS. 50-317(318)/96-07-02 i

BREACIIED SHIPPING CONTAINER Notice of Violation Nos. 50-317/96-07-02 and 50-318/96-07-02 describes a non-conformance involving the loss ofintegrity of a radioactive materials shipment. The Notice of Violation States, in part, that:

i "10 CFR 71.5 requires, in part, that licensees who transport licensed material outside the i

confines of its plant or other place of use comply with the applicable requirements of 49 CFR 170 through 189. 49 CFR 173.421(a)(1) requires that packages used to ship excepted limited quantities of Class 7 (radioactive) material comply with the generalpackage design i

requirements of 49 CFR 173.410. 49 CFR 173.410 requires, in part, that each package used to i

ship Class 7 (radioactive) material be designed such that the package will be capable of withstanding the efects of any vibration or acceleration that may arise under normal conditions oftransport, without deterioration in the effectiveness ofthe package.

Contrary to the above, on May 24,1996, the licensee shipped a package (Radioactive Shipment No. 96-00066) containing Class 7 (radioactive) materials, which subsequently arrived at its destination on May 29,1996, with a 5 to 6 inch hole on the smderside ofthe package. "

I.

REASON FOR THE VIOLATION On May 24,1996 Baltimore Gas and Electric Company shipped radioactive material from the Calvert Cliffs Nuclear Power Plant to Chem Nuclear Systems Inc. of Barnwell, South Carolina which upon receipt inspection was found to have a 5 to 6 inch hole on the underside of the sea-land container on the transport truck. No contamination was found external to the hole in the floor of the sea-land container.

He radioactive material consisted of an excepted package-limited quantity shipment (UN2910) containing scaffold material contaminated with solid metal oxides and was packaged and shipped in a 20-foot sea-land container loaded on a transport vehicle. Upon receipt of the container, Chem-Nuclear Systems Inc. performed a receipt survey and found the discrepancy. Baltimore Gas and Electric Company was then notified of the discrepancy.

Chem-Nuclear Systems Inc. inspected the container to see if the scaffolding had shifted and caused the hole in the wooden floor. It was determined that a vendor supplied scaffold rack had placed a 1

concentrated load at the location of one of the scaffolding rack wheels and had caused the hole in the container flooring. Further investigation was performed at Calvert Cliffs Nuclear Power Plant to t

determine why the contents had shifted during transport. The investigation determined the scaffolding was properly packaged and internally braced prior to shipment. The investigation also determined that an emergency stop could have resulted in the damage, however, the carrier did not substantiate this finding, but did convey that the travel route did include rough construction areas.

The primary cause of this violation was the failure to place sufficient load bearing surfaces under the scafTold rack wheels which would preclude the puncturing of the wooden floor of the sea-land container.

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ATTACIIMENT (1)

REPLY TO NOTICE OF VIOLATION NOS. 50-317(318)/96-07-02 BREACIIED SHIPPING CONTAINER II.

CORRECTIVE STEPS TAKL AND RESULTS ACIIIEVED in response to this event, the General Supervisor-Radiation Safety issued a memorandum to the i

Materials Processing Supervisor on August 8,1996, directing immediate actions to be taken to prevent further occurrences These actions included, in part, inspecting all appropriate containers to ensure internal bracing and flooring is adequate to assure that load bearing surfaces will support the materials within the package. The use of weight distributing plates or other means will be required when i

necessary to prevent punching holes in shipping containers.

In addition, the owner of the sea-land container, RUST Scaffold Rental, was notified of the apparent concentrated floor loading problem with the shipment and the need to specify packaging requirements for scaffold racks or similar shipments. Baltimore Gas and Electric Company requested RUST to inform other users of sea-land containers of this issue to prevent similar occurrences.

)

Ill.

CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS The following changes have been made to Radiation Safety Procedures (RSP-2-204 and RSP 2-202)

A.

All packages and containers of radioactive material will be inspected prior to shipment to ensure the material inside is properly stabilized to prevent shifting during transport.

Special care will be taken to inspect for heavy concentrated loads which could perforate the package. The use of weight distributing plates or othcr means will be required when necessary to prevent punching holes in shipping containers. This inspection will either be performed prior to shipment or when the material is originally packed.

B.

Additional instructions will be provided to the drivers of radioactive material shipments j

to notify Baltimore Gas and Electric Company (shipper) of any instances where an emergency stop has occurred which may cause a lod to shift in transit.

Radiation Safety personnel have beca briefed on the cause and corrective actions associated with this event and lessons learned have been incorporated into the Radiation Safety Technician Continuing Training Program.

Baltimore Gas and Electric Company has distributed a notice of the problem on the Nuclear Network to make other utilities aware of this issue.

IV.

DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved on August 8,1996 when inspection criteria were implemented via the General Supervisor-Radiation Safety memorandum.

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