ML20214T609

Responds to Violations Noted in Insp Rept 50-413/87-11. Corrective Actions:Radiation Survey Sheets Revised to Include Labeled Area for Listing One Meter,Two Meter & Cab Readings

ML20214T609
Person / Time
Site:	Catawba
Issue date:	06/01/1987
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
IEB-79-19, NUDOCS 8706100344
Download: ML20214T609 (4)

Text

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4 DUKE POWER GOMPAhT P.O. HO x 33180 CHARLOTTE, N.C. 28242 HALB. TUCKER retrynosa M etts N T (704) 373-4533 mmaan reonas. vion June 1, 1987

-U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

RII: CHB Catawba Nuclear Station Docket Nos. 50-413 and 414 Violation 413/87-11-01

Dear Sir:

Please find attached our response to the subject Violation.

Very truly yours, gz Hal B. Tucker LTP/53/sbn Attachment xc: Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station

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V DUKE POWER COMPANY RESPONSE TO VIOLATION 50-413/87-11-01 Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering applicable procedures recommended in Appendix A or Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Regulatory Guide 1.33, Paragraph G.S.C states that the licensee should have radiation survey procedures.

Radiation Control Procedure HP/0/B/1006/12, Shipment of Dewatered Resins, dated April 2, 1987, requires in Step 4.12.1 that an exit survey be performed on a loaded vehicle and that radiation levels be listed for points: (1) one-half inch (contact) and two meters from the vertical plane projected from the outer edges of the vehicle and (2) inside the cab.

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

1. The results of radiation surveys performed inside the cab for radioactive material shipments LBD 87-13 on February 23, 1987, and CNS 87-21 on March 20, 1987, were not listed on the survey data sheets, and

2. The results of radiation surveys performed at a point two meters from the vertical plane of the vehicle for radioactive material shipments CNS 87-10 on February 6, 1987, and CNS 87-13 on February 23, 1987, were not listed on the survey data sheets.

RESPONSE

1. Admission or Denial of Violation Duke Power Company admits to the violation.

2. Reason for Violation if Admitted 49CFR173.441 states radiation levels for exclusive use shipments of radioactive material. These regulations limit the contact dose rate to 200 mrem /hr, the 2 meter dose rate to 10 mrem /hr and the truck cab reading to 2 mrem /hr (for unmonitored drivers). If the truck driver is monitored by desimetry, the limit would be based on 10CFR20 regulations which are considerably higher than 2 mrem /hr.

Radiation control procedure HP/0/B/1006/12 was written to ensure all radioactive material shipment regulations are met when making a shipment.

HP/0/B/1006/12 has the same dose rate limits as 49CFR173.441.

The shipments that were discussed in the report were all approved transport casks owned by Chem-Nuclear Systems Inc. The dose rates on these casks were as follows:

87-10 Chem-Nuclear 80 ft cask contained 2.3E4 mci Survey Top .3 mrem /hr (contact)

Side .4 mrem /hr, .5 mrem /hr and .7 mrem /hr (contact) 1 meter .1 mrem /hr

. Pcg3 2 87-13 Chem-Nuclear 120 ft cask contained 2.9E4 mci Survey Top .7 mrem /hr (contact)

Side .7 mrem /hr and .9 mrem /hr (contact)

Bottom 1.5 mrem /hr (contact) 1 meter .1 mrem /hr 1 meter toward cab < .5 mrem /hr 87-21 Chem-Nuclear 80 ft cask contained 2.4E4 mci survey Top .7 mrem /hr (contact)

Side .4 mrem /hr,1 mrem /hr and .6 mrem /hr (contact)

Bottom .7 mrem /hr (contact) 18" .4 mrem /hr 2 meters .2 mrem /hr side toward cab .6 mrem /hr The report stated 87-13 and 87-21 did not list the radiation level in the cab of the truck. Review of the surveys shows that 87-21 had a dose rate of .2 mrem /hr at 2 meters from the cask. 87-13 has a cask reading of < .5 mrem /hr at 1 meter from the package. With these low dose rates, at this close distance, the dose rate at a greater distance would be below the range of an instrument normally used for this type of survey. Therefore, after subtracting background from a cab reading, the listed radiation level for the cab would be 6 mrem /hr. Since the Chem-Nuclear truck drivers wear dosimetry, they can exceed the 2 mrem /hr regulation. The dose rate was far below any regulation limit.

The report also stated that 87-10 and 87-13 did not list a 2 meter dose level. The condition here is similar to the cab readings. Both of the casks had maximum dose rates of .1 mrem /hr at 1 meter. With these low dose rates, the 2 meter reading would be < .5 mrem /hr, far below regulation and procedural limits. Since the readings were either 6 or close to 6 mrem /hr, the dose rates were not listed on the survey sheet.

3. Corrective Action Taken and Results Achieved The surveys discussed are important to verify compliance with procedural and regulation requirements. To ensure these readings are documented when higher dose rates are a concern, the survey sheets have been changed.

The revised survey sheets have a labled area for listing 1 motor, 2 meter and cab readings. In addition to these changes, all personnel involved in shipping radioactive material have been informed of this situation.

4. Corrective Action to be Taken to Avoid Further Violations All personnel responsible for shipping radioactive material are thoroughly trained in accordance with IE bulletin 79-19 and are knowledgeable of all regulations concerning shipment. The NRC inspector felt the personnel involved in the situation were knowledgeable to do the job.

Therefore, no further training is necessary for these people.

IIP /0/B/1006/12 was changed to prevent the reoccurrence of this situation.

Section 4.12.1 is being changed to instruct personnel where to take surveys and require documentation per our survey procedure.

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5. Date of Full Compliance Duke Power Company is in full compliance with all regulations and procedural

, requirements at this time.

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