ML20138J416

Notice of Violation from Insp on 970210-0307.Violation Noted:Licensee Offered for Transportation by exclusive-use, Closed Transport Vehicle,Package Which Arrived Having Max Surface Radiation Levels Exceeding 10 Msv/Hr

ML20138J416
Person / Time
Site:	Vogtle
Issue date:	04/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138J391	List: ML20138J386 ML20138J416
References
50-424-97-02, 50-424-97-2, 50-425-97-02, 50-425-97-2, EA-97-129, NUDOCS 9705080203
Download: ML20138J416 (19)

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NOTICE OF VIOLATION Southern Nuclear Operating Co., Inc. Docket Nos. 50-424 and 50 425 Vogtle Nuclear Plant License Nos. NPF 68 and NPF 81 -

EA 97-129 During an NRC inspection conducted on February 10 14, and March 3 7, 1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

10 CFR 71.5(a) requires that a licensee who transports licensed material outside of the site of usage, as specified in the NRC license, or where l transport is on public highways, or who delivers licensed material to a  !

carrier for transport, comply with the applicable requirements of the i

regulations appropriate to the mode of transport of the Department of 1 2

Transportation (DOT) in 49 CFR Parts 170 through 189. '

, 49 CFR 173.475 requires, in part, that before each shipment of any Class i

7 (radioactive) materials package, the offeror must insure by i

, examination or appropriate tests, that the external radiation and

contamination levels are within the allowable limits in 49 CFR Parts l

171 178. 49 CFR 173.441(b) requires in part, that each package of l 4

radioactive material offered for transportation by exclusive-use, closed transport vehicle, be designed and prepared for shipment so that under conditions normally incidant to transportation the radiation level does not exceed 10 millisievert per hour (1000 millirem per hour) at any point on the external surface of the package.

Contrary to the above, on October 23, 1996, the licensee offered for transportation by exclusive-use, closed transport vehicle, a package which arrived at its destination having maximum surface radiation levels exceeding 10 mSv/hr (1000 mrem /hr). Specifically, on October 29, 1996

radiation surveys of the unopened packages at the final destination measured a maximum external surface dose rate of approximately 20 mSv/hr (2000 mrem /hr).

This is a Severity Level IV violation (Supplement V).

Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regicnal Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence if the correspondence adequately 9705080203 970425 Enclosure 1 PDR ADOCK 05000424 G PDR

Notice of Violation 2 k addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be j issued as to why the license should not be modified, suspended, or revoked, or  !

!l why such other action as may be proper should not be taken. Where good'cause j is shown, consideration will be given to extending the response time.

Dated at Atlanta, Georgia 2

thisjdF" bay of April 1997 i

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Enclosure 1

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LIST OF ATTENDEES I Nuclear Reaulatory Commission l

{ L. Reyes, Regional Administrator, Region II (RII) ,

C. Evans, Regional Counsel, Office of Regional Administrator (0RA), RII '

, D. Collins, Acting Deputy Director, Division of Reactor Safety (DRS), RII i

K. Barr, Chief, Plant Support Branch (PSB) DRS, RII '

. P. Skinner, Chief, Division of Reactor Projects (DRP) Branch 2. RII l G. Kuzo, Radiation Specialist, PSB, DRS, R.II A. Boland, Enforcement Specialist, Enforcement and Investigations Coordination Staff (EICS), ORA, RII i F. Young, Transportation Specialist, Division of Nuclear Material and Safety l Safeguards (NHSS) 4 N. Hamish, Enforcement Coordinator, Office of Enforcement

[ Southern Nuclear Operatina Company. Inc.

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l J. Woodard, Executive Vice President, Southern Nuclear Operating Corppany, Inc.

4 (SNC) l C. McCoy, Vice President, Vogtle Electric Generating Plant (VEGP), SNC

J. Gasser, Assistant General 'hnager of Operations, VEGP, SNC 1 J.

,ailey, Manager Licensing, WC

F. Scoggins, Nuclear Specialist, VEGP, SNC Rh0Cli No Hembers of the Public Enclosure 2

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PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA VOGTLE 1

APRIL 18,1997, AT 08

45 A.M.

I NRC REGION ll OFFICE, ATLANTA, GEORGIA l a ,

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1. OPENING REMARKS AND INTRODUCTIONS i L. Reyes, Regional Administrator i 11. NRC ENFORCEMENT POLICY i A. Boland, Enforcement Specialist j Enforcement and Investigation Coordination Staff 111.

SUMMARY

OF THE ISSUES

{ L. Reyes, Regional Administrator i

IV. STATEMENT OF CONCERNS / APPARENT VIOLATION i D. Collins, Deputy Director, Division of Reactor Safety

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V. LICENSEE PRESENTATION l l  !

j j VI. BREAK / NRC CAUCUS j Vll. NRC FOLLOWUP QUESTIONS

! 3 Vill. CLOSING REMARKS L. Reyes, Regional Administrator l

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ENCLOSURE 3

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ISSUE TO BE DISCUSSED .

FAILURE TO ASSURE THAT EXTERNAL RADIATION LEVEL ON A RADIOACTIVE HATERIALS PACKAGE OFFERED FOR TRANSPORTATION HET THE LIMITS OF 49 CFR PART 173.44(b)

WHICH SPECIFIED THAT THE SURFACE DOSE RATE FOR EXCLUSIVE USE SHIPMENTS HUST

! NOT EXCEED 10 MILLISIEVETS PER HOUR (1000 MILLIREM PER HOUR). ON OCTOBER 23, l 1996. A PACKAGE SHIPPED FROM V0GTLE WAS FOUND TO HAVE APPR0XIMATELY 2000 HILLIREH/HR SURFACE DOSE RATE WHEN ORIGINALLY SURVEYED AT ITS DESTINATION.

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NOTE: The apparent violation discussed in this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement decision.

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O ENCLOSURE 3

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PREDECISIONAL ENFORCEMENT CONFERENCE RESPONSE TO APPARENT VIOLATION NUMBER 50-424,425/97-02-02

= OPENING REMARKS l

= DESCRIPTION OF INCIDENT

= CHRONOLOGY

=CAUSES ,

= SIGNIFICANCE

= HISTORICAL PERFORMANCE i

= CORRECTIVE ACTIONS  !

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@ 1. VOGTLE 8 2. WESTINGHOUSE i

$ = CLOSING REMARKS

o o ~a DESCRIPTION OF INCIDENT

= WHILE UNLOADING AT A VENDOR FACILITY, AN EXCLUSIVE USE, CLOSED TRANSPORT VEHICLE SHIPMENT OF OUTAGE EQUIPMENT FROM PLANT VOGTLE, WAS FOUND TO HAVE ONE BOX WITH DOSE RATES EXCEEDING DEPARTMENT OF TRANSPORTATION (DOT) LIMITS OF 1000 mrem /hr ON CONTACT (49 CFR 173.441(bX1)).

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O O CHRONOLOGY .

DATE

= 10/16/96 BOX NC-7337 IS PACKAGED WITH FUEL SIPPING AND RECONSTITUTION EQUIPMENT. SEVERAL ITEMS ARE WASHED DOWN NUMEROUS TIMES TO LOWER THEIR DOSE RATES.

HIGHEST DOSE RATE ON AN ITEM IS 800 mrem /hr. ITEMS ARE ARRANGED TO MINIMlZE DOSE RATES ON OUTSIDE OF BOX.

= 10/18/96 SURVEY OF BOX FOR SHIPMENT SHOWS HIGHEST CONTACT READING ON OUTSIDE OF BOX TO BE 120 mrem /hr.

= 10/23/96 SHIPMENT 96-10-005 LEAVES PLANT VOGTLE BOUND FOR WALTZ MILL, PA. HIGHEST CONTACT DOSE RATE ON TRAILER RELEASE SURVEY IS 40 mrem /hr.

= 10/25/96 SHIPMENT 96-10-005 ARRIVES AT WALTZ MILL, PA. ALL DOSE RATES ON THE OUTSIDE OF THE TRAILER ARE WITHIN REGULATORY REQUIREMENTS.

= 10/25-10/29/96 TRAlLER AWAITING OFF LOADING AT WALTZ MILL FAC:LITY. THIS IS A NORMAL PROCEDURE FOR WESTINGHOUSE. TRAILER IS UNLOADED ACCORDING TO THE NEED FOR THE EQUIPMENT.

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CHRONOLOGY i

DATE

= 10/29/96 WESTINGHOUSE BEGINS REMOVING BOXES FROM TRAILER USED IN SHIPMENT 96-10-005. BOX NC-7337 IS FOUND TO HAVE A CONTACT DOSE RATE OF 2000 mrem /hr. TH!S DOSE RATE EXCEEDS 49 CFR 173.441(b)(1). THE LIMIT IS 1000 mPem/hr '

CONTACT PER PACKAGE IN A CLOSED TRANSPORT TRAILER, EXCLUSIVE USE SHIPMENT.

= 10/30-11/4/96 WESTINGHOUSE PERFORMS INTERNAL INVESTIGATION TO IDENTIFY IF CHANGE IN PACKAGE DOSE RATES OCCURRED DURING TRANSPORT OR DURING STORAGE AND OFF-LOADING AT WALTZ MILL.

= 11/5/96 WESTINGHOUSE CONTACTS HP SUPERVISOR AT VOGTLE REGARDING DOSE RATES ON BOX. WESTINGHOUSE SUGGESTED THE PACKAGE MAY HAVE SHIFTED DURING UNLOADING. THERE WAS NO INDICATION OF A PROBLEM DURING TRANSIT. HP SUPERVISOR CONFIRMS THE SURVEY DATA AND ASKS FOR COPIES OF THEIR SURVEYS FOR US TO EVALUATE.

= 11/6/96 AFTER FURTHER INVESTIGATICN AT WALTZ MILL, WESTINGHOUSE NOTIFIES REGION 1 NRC THAT THEY RECEIVED A PACKAGE FROM .

PLANT VOGTLE THAT EXCEEDS LIMITS GIVEN IN 49 CFR 173.441(b)(1). REGION I NOTIFIES REGION 11.

CHRONOLOGY .

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> = 11/7/96 REGION ll CALLS VOGTLE. SITE CONTACT IS NOT AWARE OF PREVIOUS COMMUNICATION WITH WESTINGHOUSE OR THAT REGION I HAD BEEN NOTIFIED OF THE SITUATION. SITE CONTACT INVESTIGATES MATTER, TALKS TO WESTINGHOUSE, RECEIVES SURVEYS, WRITES DEFICIENCY CARD, BRIEFS SITE !NSPECTOR AND CALLS REGION ll WITH UPDATED STATUS.

= 11/11/96 PLANT VOGTLE DISPATCHES A SHIPPING SPECIALIST TO WALTZ MILL, PA TO INVESTIGATE THE INCIDENT. ,

= 11/12/96 SHIPPING SPECIALIST SURVEYS BOX USING AN INSTRUMENT FROM PLANT VOGTLE. FINDS CONTACT DOSE RATES OF 5000  !

mrem /hr IN A VERY LOCAllZED SPOT ON THE BOX.

= 11/12/96 BOX IS OPENED, CONTENTS REMOVED AND SURVEYED TO DETECT j SOURCE OF HIGHEST DOSE RATES IN THE BOX. A 12 FOOT LONG, 1 INCH DIAMETER PIPE IS DISCOVERED TO HAVE A DOSE RATE OF 5000 mrem /hr,1 INCH FROM ONE END. i

= 1/31/97 WESTINGHOUSE FLUSHES THE PIPE TO EXTRACT THE HIGH ACTIVITY " PARTICLE". GAMMA SPECTROSCOPY RESULTS IDENTIFY - Co-60, Zr-95, Nb-95, Ru-103, Ru-106, Cs-134, & Cs-137.

PARTICLE IS MICROSCOPIC. ,

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CAUSES 1 .

= NORMAL PRACTICE FOR ALL EQUIPMENT REMOVED FROM THE SPENT FUEL POOL IS TO FLUSH, ALLOW TO DRIP-DRY, AND EXTERNALLY WIPE DOWN. TYPICALLY, INACCEGSIBLE INTERNAL SURFACES ARE NOT WIPED DOWN OR ALLOWED TO DRY PRIOR TO PACKAGING AND SHIPPING.

= DOSE RATES ON BOX CONTAINING GUIDE TUBE WERE ACCEPTABLE WHEN BOX WAS PACKAGED AND SHIPPED. AT SOME POINT DURING THE TIME INTERVAL BETWEEN THE TRAILER LEAVING SITE (OCT. 23)

AND UNLOADING AT THE VENDOR FACILITY (OCT. 29), CONDITIONS

!NSIDE THE GUIDE TUBE CHANGED.

= DOSE RATES ON MICROSCOPIC DISCRETE PARTICLES ARE HIGHLY DIRECTIONAL AND GEOMETRY DEPENDENT.  !

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= DOSE RATES ON THE OUTSIDE OF THE TRANSPORT TRAILER 1 REMAINED WITHIN REGULATORY LIMITS AT ALL TIMES DURING TRANSPORT.

= AT NO TIME WAS THE PUBLIC AT RISK DURING TRANSPORTATION OF THIS EQUIPMENT.

= NO OVEREXPOSURE, OR UNPLANNED EXPOSURE OCCURRED DURING THE HANDLING OF THIS EQUIPMENT.

= THE MICROSCOPIC DISCRETE PARTICLE WAS CONTAINED WITHIN THE GUIDE TUBE, THEREFORE, THERE WAS NO DANGER OF SKIN EXPOSURE.

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HISTORICAL PERFORMANCE

-r l = PLANT VOGTLE PERFORMS AN AVERAGE OF 160 RADIOACTIVE MATERIAL SHIPMENTS PER YEAR, APPROXIMATELY 1600 SHIPMENTS IN 10 YEARS OF OPERATING EXPERIENCE AND, UNTIL NOW, HAS NEVER l HAD A TRANSPORTATION (49 CFR) VIOLATION.

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O O CORRECTIVE ACTIONS .l VOGTLE

= POLICY ESTABLISHED FOR HP AND DECON PERSONNEL REQUIRING THAT ITEMS BEING REMOVED FROM THE SPENT FUEL POOL BE ALLOWED TO DRY PRIOR TO BEING SURVEYED, WRAPPED AND PACKAGED FOR SHIPMENT.

= TRAINING CONDUCTED FOR HP STAFF REGARDING SURFACE CONTAMINATED OBJECT (SCO) SHIPMENTS STRESSING THE NEED TO ENSURE THAT " HOT SPOTS" ARE IDENTIFIED AND SHIELDING APPLIED IF NECESSARY.

CORRECTIVE ACTIONS .

.I WESTINGHOUSE:

= PRIOR TO NEXT REFUELING OUTAGE, DEVELOP MATERIAL AND TOOL CLEANLINESS PROCEDURES TO ENSURE THAT MATERIALS ARE PROPERLY DRIED PRIOR TO WRAPPING AND PACKING IN BOXES (DRAFT PROCEDURE DUE 6/6/97)

= INVESTIGATE THE POSSIBILITY OF SHIELDING THE BOXES THAT TRANSPORT FUEL SIPPING AND RECONSTITUTION EQUIPMENT (EVALUATION IS ONGOING - ACTION ITEM DUE 8/31/97) o i

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