ML20197J125
| ML20197J125 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/24/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jeffery Wood CENTERIOR ENERGY |
| References | |
| 50-346-97-12, NUDOCS 9801020088 | |
| Download: ML20197J125 (2) | |
See also: IR 05000346/1997012
Text
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December 24, 2997
Mr. John K. Wood
Vice President - Nuclear
Davie-Besse Nuclear Power Station
Centerior Sorvice Company
5501 North State - Route 2
Oak Harbor, OH 43449
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPOR r 50-346/97012(DRS))
Dear Mr. Wond:
- This will acknowledge receipt of your letter dated December -4,1997, in response to our
letter dated November 4,1997, transmitting a Notice of Violation for improperly transporting a
Class 7 (radioactive) material package as a package excepted from the specification
packaging, marking, and labeling requirements, and the shipping paper and certification
requirements. This package had external package readings of up to 0.025mSv/hr which
exceeded the 0.005mSv/hr maximum radiation lim;t on the external package required for
excepted packages in 49 CFR 173.421. 'No have reviewed your corrective actions for the
violation and have no further questions at this time, These corrective actions will be examined
during future inspec; ions.
Sincerely,
original signed by R. N. Cardner g
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-346
Enclosure:
Ltr dtd 12/4/97 J. K. Wood
Davis Besse to USNRC
See Attached Distribution
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DOCUMENT NAME:G:DRS\\DAV122_7.DRS
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J. K. Wood
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December 24. 1997
- cc w/o encl:
J. P. Stetz, Senior Vice President - Nuclear
- J. H. Lash, Plent Manager
J. L; Freels, Manager, Regulatory Affairs --
State Liaison Officer, State of Ohio
Robert E. Owen, Ohio Department of Health
cc w/ encl:
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C. A. Glazer, State of Ohio
Public Utilities Commission
Roy P. Lessy, Jr., Esq.
Distributl0D
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Docket File w/ encl
Rlli PRR w/enci
Rlli Enf. Coordinator w/enci
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PUBLIC IE-01 w/ encl
SRI, Davis Besse w/ encl
TSS w/ encl
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LPM, NRR w/enci
J. L. Caldwell, Rill w/ encl
DOCDESK w/enci
DRP w/ encl
A. B. Beach Rlll w/enci
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John K. Wood
oak Hartsar.OH 43449
FAA: 4194$14337
Vate *rescent . Nucler
Davis-Besse -
. Docket Number 50-346
License Number NPF-3
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Serial Number 1-1144
December 4, 1997
- United States Nuclear Regulatory Commission
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Document Control Desk
= Washington, D.C. 20555 001
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Subject: Response to Inspection Report 50-346/97012 and Notice of Violation
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Ladies and Gentlemen:-
This letter and its attachment provides Toledo Edison's (TE) response for the Davis-Besse Nuclear
Power Station, Unit 1 (DBNPS), to the Notice of Violation contained within Nuclear Regulatory
Commission's (NRC) Inspection Report 50-346/97012 (Log 1-3911), dated November 4,1997.
Inspection Report 50-346/97012 presented the results of the routine Radiation Protection and
Chemistry Inspection conducted from October 6,1997 through October 10,1997 at DBNPS. On
August 28,1997, DBNPS improperly transported a Class 7 (radioactive) material package as a
package excepted from the specification packaging, marking and labeling requirements, and the
shigg.ing paper and certification requirements. This package had external package readings of up to
0.025mSv/hr which exceeded the 0.005 mSv/hr maximum radiation limit on the external package
required for excepted packages in 49CFR173.421.
If you have any questions or require additional information, please contact Mr. James L. Freels,
Manager - Regulatory Affairs, at (419) 321-8466.
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Very truly yours,
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Attachment
.IAc.,-,, ,, y vmwwm k?7"T":iBkteach, RegionalMinlestor,?NRC Region IHs
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cc:
- S. J. Campbell /DB;1'NRC Senior Resident Inspeitor
A. G. Hansen, NRC Project Manager
LUtility Radiological Safety Board
DEC 0 81997
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Decket Number 50-346 ,
License Number NPF-3 -
Serial Number 1 1144--
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- Attachrnent 1
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Rep!v to a Notice of Violation (50-346/97012L
' Restatement of Allened hiolati28
- "10 CFR 71.5(a) requires that, in part, that each licensee who transports licensed materials
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outside the site of usege, or 'vhere transport is on public highways, or who delivers licensed.
material to a carrier for transpod, shall comply with the applicable requirements of the : . .
Depanment of Transportation regulations in 49CFR Paru 170 through 189 eppropriate to the -
- mode of transport. .
- 49CFR173.421 (a)(2) requires, in part, that a Class 7 (radioactive) material whose activity per-
package does not exceed the limits specified in 49CFR173.425 and its packaging are excepted
from the specification packaging, marking, labeling, and ifit is act a hazardous substance or
hazardous waste, the shipping papei and certification requirements, if the rauiation level at any
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point on the external surface of the package does not exceed 0.005mSv/ hour (0.5 mrem / hour).
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- Contrary to the above,'on August 28,1997, the licensee improperly transponed a Class 7
(radioactive) material package as a package excepted from the specification packaging, marking
and labeling requirements, and the shipping paper and certification requirements. Specifically,-
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. this package had external package readings of up to 0.025mSv/hr which exceeded the 0.005
mSv/hr maximum radiation limit on the external package required for excepted packages in
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49CFR173.421.
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This is a Severity Level IV violation (Supplement V)."
Reason for the Violation
On August 27,1997, Davis Besse Nuclear Powa- Station (DBNPS) persormel initiated
preparation of a shipment of three boxes containing contaminated lead shielding. These boxes
were to be loaded on a truck for shipment to the Perry Nuclear Power Plant (PNPP) the next day.
The material was to be sent as Department of Transportation (DOT) classified " Limited
- Quantity" in accordance with 49CFR173.421, radioactive material with a maximum dose rate of-
0.005 mSv/hr. -
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On August 28,1997, Radiation Protection (RP) Tester (B) was assigned to perform the final
- extemal shipping surveys. Tester B obtained an Extender 2000W (Extender) survey instrumerit
. and relieved RP Tester (A). During the verbal turnover, Tester B was told that there were no .
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problems with the shipment, L Dose rate values were not discussed.
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Docket Number 50-346 -
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License Number NPF-3
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Serial Number 1 1144
- Attachment 1
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- Page 2 of 3 -
' During the box survey, the Radioactive Material Shipping Coordinator arrived at thejob site and
- told Tester B that the boxes were to be shipped " Limited Quantity," dose rates less than :
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0.5 mrem / hour at the extemal box surface.
While surveying box PB 07, Tester B noted that the Extender survev instrument indicated
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2.5 mrem /hr. Since this was higher than the anticipated dose rate for a " Limited Quantity"
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' shipment, Tester B obtained another type of survey instrument, Bicron Micro Remeter
- (MicroRem), to perform comparative testing. During the survey with the MicroRem, Tester B -
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. noted that the maximum dose rate for Box PB-07 was 0.25 mrem /hr.
The Radioactive Material Shipping Coordinator and the RP Servicemen Supervisor were
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/ supervising the surveys and the loading of the material. They were aware that there was a
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discrepancy between the survey instruments. They followed up with Tester B after the
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MicroRem readings were obtained,' but only verified that the second survey had been performed
and no problems were noted. Neither Tester B, the Radioactive Material Shipping Coordinator,
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- nor the RP Servicemen Supervisor informed the RP Supervisor that there had been a discrepancy
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between instmments. The RP Supervisor reviewed the survey documentation without
knowledge of the higher dose rate indicstions from the Extender,
Once the surveys were completed, the three boxes were loaded and the shipping paperwork was
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prepared and reviewed. At 1105 hours0.0128 days <br />0.307 hours <br />0.00183 weeks <br />4.204525e-4 months <br /> on August 28,1997, the shipment departed DBNPS for -
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PNPP. At approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, the shipment arrived at PNPP and a receipt survey was
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initiated. During the Receipt survey, it was discovered that one cornar of Box PB-07 had a dose
- rate of 2.5 mrem / hour. The PNPP personnel verified this dose rate with both independent
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instruments and personnel.
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At approximately 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, PNPP RP Management notified DBNPS Management and the
PNPP NRC Resident Inspector that the comer of Box PB-07 read 2.5 mrem / hour, exceeding the
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DOT " Limited Quantity" limit of 0.5 mrem /hr.-
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Once PNPP discovered the higher than expected dose rates, DBNPS coordinated with PNPP to -
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ensure proper handling of Dox PB-07. Potential Condition Adverse to Quality Report (PCAQR)
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97-1158 was initiated on August 29,1997, and an investigation ensued.
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The two DBNPS survey instruments utilized by Tester B on August 28,1097, were isolated and
tested. The response and calibration checks were satisfactory _ for both instruments, indicating
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.prr-per instrument performance. Personnel involved in preparation of the shipment were
inteniewed. The DBNPS RP Management also investigated the performance of radiological
surveys associated with the shipment to PNPP and all radioactive shipments being processed at
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Docket Number 50-346
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- License Number NPF.3
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. Serial Number 1 1144
' Attachment I-
Page 3 of 3
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The inves'igation concluded that the cause of this event was an _ inadequate s.urvey caused by
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personnel error in using the survey instrument. The Bicron MicroRem has an analog meter scale
which provides readings of microrem/hr in multiples of ten, depending on die operator selected
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range scale, it was determined that Tester B utilized the incorrect r,caling factor, thus causing the
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incorrect dose rates to be recorded.
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Tester B dld not question the difference between the two meter readings. Tester B incorrectly
- believed that the higher Extender readings were attributed to background fluctuations at the low
end of the meter scale. Tester B then utilized a more sensitive instrumert, the MicroRem, and
obtained, erroneously, a aose rate that he anticipated based on previous infoimation.
Conective Actions Taken and Results Achieved
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Based on the findings of the investigation, the RP personnel involved i a this event have been
counseled on personnel error prevention. Radiation Protection Standir.g Order 97-0005 was
issued on September 2,1997, requiring two independent radiological s urveys for all radioactive
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material shipments. To determine the extent of condition, DBNPS PCAQRs for the previous
three years were reviewed. No additional occurrences of survey instmment reading
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misinterpretation associated with radioactive material shipping were identified.
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Corrective Actions to Prevent Recurrence
Based on the PCAQR review, it was determined that this was an isolated incident involving
personnel error in using a radiological survey instrument and the RP personnel involved in this
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event were counseled.
In addition, a " Barriers to Inappropriate Shipments" round table discussion with the RP
management staff was conducted to discuss Root Cause Analysis and ensure that the cause of the
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error was understood and that appropriate corrective actions were taken. Furthermore,
DB-IIP-01500," Radioactive Material Shipping," was revised to specify the survey instnunent to
be utilized, an Extender 2000W, and to require two independent radiological surveys for all
radioactive material shipments. This revision was effective October 9,1997. This event is being
communicated to the RP staff during the current training cycle. This training includes a review
of PCAQR 97-1158, the current effective revision of DB-HP-01500 and the lessons learned.
~ This training is scheduled to be completed by December 31,1997. -
- Date When Full Comnliance Will be Achieved
Full compliance was achieved on August 28,1997, when box PB-07 was secured at PNPP and
was no longer in transit.