ML20148C844
| ML20148C844 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/20/1997 |
| From: | Mccoy C SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-424-97-02, 50-424-97-2, 50-425-97-02, 50-425-97-2, EA-97-129, LCV-1023-A, NUDOCS 9705290173 | |
| Download: ML20148C844 (3) | |
Text
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c C. K. McGey South:rn Nucirr Vce President Operating Company,1:c.
vo92 Project 40invemess Center Parkway P.O. Box 1295 Birmingham. Alabama 35201 Tel 205.992.7122 Fax 205 992.0403 SOUTHERN Ra COMPANY May 20, 1997 5,,,gy go r. u you,wortg=
Docket No.
50-424 50-425 i
LCV-1023-A U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REPLY TO A NOTICE OF VIOLATION Pursuant to 10 CFR 2.201, Southern Nuclear Operating Company (SNC) submits the enclosed
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information for Vogtle Electric Generating Plant (VEGP) in response to enforcement action EA 97-129, for the violation identified in Nuclear Regulatory Commission (NRC) Inspection Report Nos. 50-j 424; 425/97-02, and identified during an inspection conducted from Febmary 10-14 and March 3-7, 1997. In the enclosure, a transcription of the violation precedes SNC's response.
Should you have any questions feel free to contact this office.
Sincerel,
L9 iM '
C. K. McCoy CKM/CTT/afs
Enclosure:
Reply to NOV 50-424;425/ 97-02 (EA 97-129) cc: Southern Nuclear Operating Company Mr. J. B. Beasley, Jr.
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Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle n t') n n O 1 9705290173 970520 lilllllilllllllIllll!llllllllllj lilllihl1l lll PDR ADOCK 05000424 11111111:191hllutiltillll4 O
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.c ENCLOSURE l
VOGTLE ELECTRIC GENERATING PLANT - UNITS 1 & 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-02 i
l VIOLATION 50-424: 425/97-02 (EA 97-129)
The following is a transcription of the violation as cited in the Notice of Violation (NOV):
"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 transport is on public highways, or who delivers 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 Parts 170 through 189.
49 CFR 173.475 requires, in part, that before each shipment of any Class 7 (radioactive) materials package, the offeror must insure by examination or appropriate tests, that the external radiation and contamination levels are within the allowable limits in 49 CFR Parts 171-178. 49 CFR 173.441 (b) requires in pad, that each package of radioactive material offered for transportation by exclusive-use, closed transport vehicle, be designed and prepared for shipment so that under conditions normally incident 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 j
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 j
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)."
RESPONSE TO VIOLATION 50 424: 425/97-02 (EA 97-129_J Admission or Denial of the Violation:
This violation occurred as stated in the notice of violation.
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Reason for the Violation:
I On October 16,1996, an exclusive-use, closed transport vehicle radioactive materials package, which included refueling outage equipment, was prepared for offsite shipment.
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ENCLOSURE l
VOGTLE ELECTRIC GENERATING PLANT-UNITS 1 & 2 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORTS 50-424: 425/97-02 At the time the package was prepared, the normal practice for preparing equipment which had been stored in the Spent Fuel Pool, was to flush, allow to drip-dry, and wipe down external surfaces. Typically, inaccessible internal surfaces are not wiped down or allowed to dry prior to packaging and shipping.
On October 23,1996, the package was surveyed and shipped offsite. Dose rates on the package containing the guide tube were acceptable when the package was prepared and shipped. At some point during the time interval between the transport trailer leaving VEGP on October 23,1996, and unloading at the vendor facility on October 29,1996, conditions inside the guide tube changed. Dose rates which exceeded the DOT limits on the external surface of the package were discovered when the box was unloaded. Dose rates on the outside of the transport trailer remained within regulatory limits at all times during transport.
A detailed investigation identified a microscopic discrete particle contained within the guide tube. The probable cause of the changes in radiological conditions inside the guide tube could be attributed to the guide tube not being completely dry prior to packaging. As the tube dried out, the particle changed geometry during transpon or handling at the vendor facility which created the higher dose rates.
Corrective Stens Which llave Been Taken and the Results Achieved:
1 1.
A policy was established for health physics and decontamination personnel requiring that items being removed from the Spent Fuel Pool be allowed to by prior to being surveyed, wrapped and packaged for shipment.
2.
Training was conducted for health physics personnel regarding surface contaminated object shipments stressing the need to ensure that " Hot Spots" are identified and shielding applied as necessary.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
Prior to the IR7 refueling outage, which is scheduled to begin in September 1997, the refueling services vendor will develop material and tool cleanliness procedures to properly dry packages prior to shipment for any equipment shipped from VEGP.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved on October 29,1996, when the package was identified to be over the DOT limits at the vendor facility.
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