ML20202F768
| ML20202F768 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/04/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1144, 50-346-97-12, NUDOCS 9712090221 | |
| Download: ML20202F768 (4) | |
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I 5501 N State F4oule 2 419 249-2300 John K. Wood Oak Ha'bor.OH 43449 FAX: 419-3218337 Vice Pres (1ert. Nucleat Davis-Besse Docket Number 50-346 License Number NPF-3 Serial Number 1-1144 December 4, 1997 United States Nuclear Regulatory Commission
- Document Control Desk Washington, D.C. 20555-001
Subject:
Response to Inspection Report 50-346/97012 and Notice of Violation 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 Nuc!:ar 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 inspe'. tion 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 shipping 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 infonnation, please contact Mr. James L. Freels, Manager - Regulatory Affers, at (419) 321-8466.
Very truly yours,
/
7 th 4 @l CAk/d c Attichment A. B. Beach, Regional Administrator, NRC Region III cc:
S. J. Campbell, DB-1 NRC Senior Resident inspector A. G. Hansen, NRC Project Manager Utility Radiological Safety Board ll ll llll lllll.lllll.
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9712090221 971204 PDR ADOCK 05000346 G
PDR I
- Docket Number 50-346 License Number NPF-3 Serial Number 1-1144 Page1 of3 Reply to a Notice of Violation (50-346/97012)
Restatement of Alleced Violation "10 CFR 71.5(a) requires that, in part, that each licensee who transports licensed materials outside the site of usage, or where transport is on public highways, or who delivers licensed material to a carrier for transport, shall comply with the applicable req #ements of the Department of Transportation regulations in 49CFR Parts 170 through 189 appropriate to the mode of transport.
49CFR173.421 (a)(2) requires, in part, that a Class 7 (radioactive) matcrial 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 not a hazardous substance or hazardous waste, the shipping paper and certification requirements, if the radiation level at any point on the external surface of the package does not exceed 0.005mSv/ hour (0.5 mrem / hour).
Contrary to the above, on August 28,1997, the licensee improperly transported 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, this package had extemal 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 packars in 45CFR173.421.
This is a Severity Level IV violation (Supplement V)."
Reason for the Violation On August 27,1997, Davis Besse Nuclear Poozer Station (DBNPS) personnel 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 40CFR173.421, radioactive material with a maximum dose rate of 0.005 mSv/hr.
On August 28,1997, Radiation Protection (RP) Tester (B) was assigned to perform the final external shipping surveys. Tester B obtained an Extender 2000W (Extender) survey instrument and relieved RP Tester (A). During the verbal turnover, Tester B was told that there were no problems with the shipment. Dose rate values were not discussed.
- Bocket Number 50-346 License Number NPF-3 Serial Number 1-1144 Page 2 of 3 During the box survey, the Radioactive Material Shipping Coordinator arrived at the job site and told Tester B that the boxes were to be shipped " Limited Quantity," dose rates less than 0.5 mrem / hour at the external box surface.
While surveying box PB-07, Tester B noted that the Extender survey instrument indicated 2.5 mrem /hr. Since this was ~.agher than the anticipated dose rate for a " Limited Quantity" shipment, Tester B obtained another type of survey instrument, Bicron Micro Remeter (MicrcRem), to perform comparative testing. During the survey with the MicroRem, Tester B 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 supervising the surveys and the loading of the material. They were aware that there was a discrepancy between the survey instruments. They followed up with Tester B after the 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, nor the RP Servicemen Supervisor informed the RP Supervisor that there had been a discrepancy between instruments. The RP Supervisor reviewed the survey documentation without knowledge of the higher dose rate indications from the Extender.
Once the sur veys. were completed, the three boxes were loaded and the shipping paperwork was 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 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 initiated. During the Reccipt survey, it was discovered that one corner of Box PB-07 had a dose -
rate of 2.5 mrem / hour. The PNPP personnel verified this dose rate with both independent instruments and personnel.
At approximrtely 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 corner of Box PB-07 read 2.5 mrem / hour, exceeding the DOT " Limited Quantity" limit of 0.5 mrem /hr.
Once PNPP discovered the higher than expected dose rates, DBNPS coordinated with PNPP to ensure proper handling of Box PB-07. Poter.tial Condition Adverse to Quality Report (PCAQR) 97-1158 was initiated on August 29,1997, and an investigation ensued.
The two DBNPS survey instruments utilized by Tester B on August 28,1997, were isolated and tested. The response and calibration checks were satisfactory for both instruments, indicating proper instrument performance. Personnel involved in preparation of the shipment were interviewed. Tne DBNPS RP Management also investigated the performance of radiological surveys associated with the shipment to PNPP and all radioactive shipments being processed at that time.
Dockct Number 50-346
' License Number NPF-3 Serial Number 1-1144 Page 3 cf 3 The investigation concluded that the cause of this event was an inadequate survey caused by personnel error in using the su'vey instrument. The Bicron MicroRem has an analog meter scale which provides readings of microrem/hr in multiples of ten, depending on the operator elected range scale. It was determined that Tester B utilized the incorrect scaling factor, thus causing the incorrect dose rates to be recorded.
Tester B did 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 instrument, the MicroRem, and obtained, erroneously, a dose rate that he anticipated based on previous information.
Corrective Actions Taken and Results Achieved Based on the findings of the investigation, the RP personnel involved in this event have been counseled on personnel error prevention. Radiation Protection Standing Order 97-0005 was issued on September 2,1997, requiring two independent radiological surveys for all radioactive material shipments. To determine the extent of condition, DBNPS PCAQRs for the previous three years were reviewed. No additional occurrences of survey instrument reading misinterpretation associated with radioactive matenal shipping were identified.
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 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 error was understood and that appropriate corrective actions were taken. Furthermore, DB-HP-01500," Radioactive Material Shipping," was revised to specify the survey instrument 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 Comoliance Will be Achievea Full compliance was achieved on August 28,1997, when box PB-07 was secured at PNPP and was no longer in transit.
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