ML20205Q148

Notice of Violation from Insp on 870209-13

ML20205Q148
Person / Time
Site:	Surry
Issue date:	03/24/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205Q116	List: IR 05000280/1987003 ML20205Q112 ML20205Q148
References
50-280-87-03, 50-280-87-3, 50-281-87-03, 50-281-87-3, NUDOCS 8704030452
Download: ML20205Q148 (4)

Text

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m ENCLOSURE 1 NOTICE OF VIOLATION Virginia Electric and Power Company Docket Nos. 50-280, 50-281 Surry License Nos. DPR-32, DPR-37 During the Nuclear Regulatory Commission (NRC) inspection conducted on February 9-13, 1987, violations of NRC requirements were identified. The violations involved failure to comply with Department of Transportation and State of South Carolina requirements regarding the transportation of licensed material, and failure to adhere to radiation controls procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. 10 CFR 30.41.c requires that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.

License Condition 26 of State of South Carolina Radioactive Material License 097, Amendment 41 requires that notwithstanding other conditions of the license, the licensee shall not accept radioactive waste for storage or disposal unless he has received advance written notification of any waste containing unusual hazards or potential hazards including but not limited to excessive removable contamination on disposal containers shipped inside casks or excessive internally contaminated casks.

License Condition 60 of State of South Carolina Radioactive Material License 097, Amendment 41 requires that unless otherwise authorized, all radioactive waste shall be received and buried in closed containers. Loose radioactive waste and solidification residuals within shipping casks are l prohibited.

Contrary to the above, the licensee failed to verify an Agreement State licensee was authorized to receive the type, form, and quantity of byproduct i material transferred in that Radioactive Waste Shipment Number 1086-198-A, I transferred to the low level radioactive waste disposal site near Barnwell, )

SC, was found upon its arrival on October 24, 1986, to contain unpackaged  !

radioactive resin and soil in the void space between the disposal liner and 8704030452 870324 PDR ADOCK 05000280 g PDR

m Virginia Electric and Power Company Docket Nos. 50-280, 50-281 Surry 2 License Nos. DPR-32, DPR-37 shipping cask. The licensee had not given the disposal site advance notification of this unusual or potential hazard.

This is a Severity Level IV violation (Supplement V). i B. 10 CFR 71.5.a requires that each licensee _who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed naterial to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.

49 CFR 172.401(a)(2) requires that no person may offer for transportation any package bearing a label specified in this subpart unless the label represents the hazardous material in the package.

49 CFR 172.403(g)(2) requires that the activity of the package, expressed in appropriate curie units must be entered in the blank -space on the Radior 'ive sabel.

49 CFR l', 310(a)(1) requires that each package of radioactive materials in excess of 0 p unds must have its gross weight plainly and durably marked on the out ir e the package.

49 CFR 173.475(- requires that before each shipment of any radioactive materials packa , the shipper shall ensure by examination or appropriate tests, that exte..ial radiation levels are within allowable limits.

49 CFR 173.441(b)(2) requires that radiation levels at any point on the outer surface of exclusive use vehicles, including the top and underside of the vehicle, must not exceed 200 millirem per hour during transportation.

r j- Contrary to the above, the licensee failed to comply with the requirements of the Department of Transportation in that:

1. Radioactive Waste Shipment Number 1186-295-A, transferred to the low level radioactive waste disposal site near Barnwell, SC was found upon its arrival on November 21, 1986, to have:

< (a) Displayed an " empty" label which did not represent an actual

condition of the package.

(b) No units of activity recorded on the Yellow II Radioactive label.

4 (c) No marking of the gross weight on the outside of the package.

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Virginia Electric and Power Company Docket Nos. 50-280, 50-281 I Surry 3 License Nos..DPR-32, DPR-37

2. No surveys of the top outer surfaces of the transport vehicles were perfonned for radioactive material shipments SEG-3 on December 17, 1986, and SH-1987-003 on February 8,1987.

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

C. Technical Specification- 6.4.D requires that radiation control procedures be followed.

Radiation Control Procedure HP 3.2.18, Temporary Low Level Waste Storage )

Facility, dated April 29, 1986, requires in Step 4.9 +. hat an inventory of .

the building be conducted at least once a quarter, that the. inventory I consist of counting each LSA box and 55-gallon drum,- that this inventory confirm the total number of containers listed in the building curie content log, and that a notation documenting the quarterly inventory be made in the I log. Step 4.10 of the procedure requires that routine surveys of the building and perimeter be performed daily when material is being moved in or:

out -of the building and weekly if no material is moved in or out of the l building. i Radiation Control Procedure HP 3.3.3.29, Calibration and Operation- of Eberline PCM-1A, dated October 9,1986, requires in Step 2.1 of Attachment 1 l that a minimum of five performance checks be made within a seven day period.

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Contrary to the above, the licensee failed to adhere to radiation control procedures in that: ,

1. There was no documentation in the building curie content log of two of the four 1986 quarterly Low Level Waste Storage Facility inventories.

2. Only radiation measurements on the exterior of the Low Level Waste Storage Facility were made for the daily surveys performed during January to February 11, 1987.

3. No performance checks were performed on the PCM-1A personnel contamination monitors between the dates of December 22 and 29,- 1986.

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

Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power is hereby required to submit to this Office within 30 days of the date of the ' letter transmitting this Notice a written statement or explanation in reply including i for each violation: (1) admission or denial of the violation, (2) the reason for i

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Virginia Electric and Power Company Docket Nos. 50-280, 50-281 Surry 4 License Nos. DPR-32, DPR-37 the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION

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Luis A. Reyes rector

/ Division of ctor Projects Dated at Atlanta, Georgia this 24 day of March 1987