ML20247K647
| ML20247K647 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/25/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0097T, 97T, NUDOCS 8906010349 | |
| Download: ML20247K647 (13) | |
Text
,. - ,
ex *
( , /
) Commonwzith Edison
'( 72 West Adams Street, Chicago, Illinois
\ [ Address Reply to: Post Office 83iiT6T
%s' Chicago, Illinois 60690 0767 April 25, 1989 L
Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subjectr Zion Nuclear Power Station Units 1 and 2 License Nos. DPR-39 and DPR-48 Response to Notice of Violation NRC Docket Nos. 50-295 and 50-304
Reference:
March 27, 1989 letter from CE Norelius to JJ O'Connor Transmitting Inspection Report Hos.
50-295/89005 a.nd 50-304/89005 Dear Mr. Davis This letter is in response to an inspection performed by Messrs.
W.J. Slawinski and R.A. Paul during the periods of December 15-16; 19-21, 1988 and j January 3-4, 1989 at Zion Station. The circumstances surrounding the two Transportation Events were also discussed at an Enforcement Conference on February 16, 1989. The conclusions drawn from the analysis of the data indicated that certain activities appeared to be in noncompliance with federal regulations. The response to these violations is provided in the Attachment to this letter.
Your cover letter expressed a concern about the adequacy of controls throughout the Edison system regarding the transportation of radioactive materials. Commonwealth Edison has generated a set of guidelines to be used at all of our facilities. These guidelines address the procedure to be followed by warehouse personnel who ship or receive radioactive material, and to also ensure that these personnel are appropriately trained to correctly respond to a radioactive material shipment. Guidance has also been established to ensure that ,
i the Shift Engineer or his designate shall verify that all appropriate documentation and surveys are complete prior to authorization of the release of the shipment. The complete guidelines are contained in Appendix A to this letter.
If you have any questions regarding this matter, please contact this {
office.
]
Very tru1} yours, i
8906010349 890425 7- - , ,
PDR ADDCK 05000295 T ' ' a'ch G PNU Nuc1 er Licensing Manager GET/sc1:0097T:1 i \
Attachment I cc: Resident Inspector-Zion APR 2 81989 .
b
A. .
., s
. ATTACHMENT
- 1. Y_lo.lAtlan 8 ,
10 CFR 71.5(a) prohibits transport of licensed material outside the confines' aof a plant or other place of use, or delivery of licensed material to a carrier'for transport unless the licensee complies'with 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.172.403(a) and 173.25(a)(2) require that each package and overpack, respectively.of. radioactive material for transportation be labeled as required with labels prescribed for the material and marked with the proper shipping
~
name and identification number. A radioactive Yellow-II label is required on packages /overpacks with surface radiation levels greater than 0.5 mrem /hr and less than or equal to 50 mrem /hr and a transport index not exceeding 1.0.
Contrary to the above, on November 18, 1988, Zion Station shipped approximately 830 microcuries of mixed isotopes to Dresden Station in an overpack.that failed to meet the prescribed marking and labeling requirements in that the overpack was not marked or labeled to indicate the contents contained radioactive material. Overpack surface and one meter radiation levels measured'on receipt were 3.7 mrem /hr and 0.3 mrem /hr, respectively, and a transport index less than or equal to 1.0.
This is a Severity Level IV violation (Supplement V),
Corrective Action Taken And Results Achieved:
The Zion Station Lead Health Physicist immediately ensured that no similar shipments were in progress or were planned. The Lead Health Physicist also discussed the event with a Warehouse Supervisor. These actions ensured no immediate recurrence of the event.
Corrective Actions Taken To Prevent Recurreneg1 Prior to any similar shipments, the Lead Health Physicist conducted a review session of radioactive materials shipment practices with all Warehouse personnel.
Detailed guidelines governing the shipment and receipt of radioactive materials were provided to Warehouse personnel. These guidelines were also later incorporated into a Zion Administrative Procedure.
l:
The applicable Zion Station Radiation Procedure was revised to require a Warehouse Supervisor's signature on common carr3 r shipping documents. This change ensures that the requirements contained in the Zion Administrative Procedure are followed when shipping this type of radioactive material.
The Zion Training Department has implemented formal recurring training for I warehouse personnel on the receipt and shipment of radioactive materials. The initial session has been completed.
f Date When_ Full Compila.nce Will Be Achievedt Zion Station is in full compliance at this time.
GET/sc1:0097T 2 li -
E_______________._________ _ __ l
_y--__ _
) .
.- i ATTACHMENT (continuell
- 2. lXialations-10 CFR 71.5(a) prohibits transport of licensed material outside the confines-of a plant or other place of use, or delivery of licensed material to a carrier for, transport unless the licensee complies with applicable requirements of the regulations appropriate to the mode of transport of the
. Department of Transportation (DOT) in 49 CPR Parts 170 through 189.
L L. 49 CFR'172.200-202 require each person who offers a hazardous material for transportation to describe the material on the shipping paper. 49 CFR 172.203(d)-describes the required additional shipping paper entries for radioactive materials.
Contrary to the above, on November 18, 1988, Zion Station offered hazardous materials consisting of radioactively contaminated equipment / parts (2.86 mil 11 curies) to a carrier for transport without any shipping papers.
This is a Severity Level IV violation (Supplement V).
fqrrective Action Taken And Results Achieved Personnel error on the part of the Radiation Technician assigned to survey this shipment resulted in release of this shipment in violation of shipping requirements.
Immediately following notification of this incident, an investigation was begun, shipment data was gathered and then relayed by phone to a ALARON Radiation Technician. The appropriate written records were then cr i.pleted o and forwarded to ALARON, Corp.
The Lead Health Physicist counseled the Radiation Protection Technician and additionally reviewed the event during a Radiation Protection / Chemistry Department Meeting to emphasize that shipping requirements be met.
In accordance with existing procedures the Zion Station Radiation Protection department issued a Radiation Occurrence Report to document and provide corrective actions concerning this event.
These actions ensured that no additional radioactive material would be released without the proper shipping documents.
Eqrrective Action Taken To Prevent Recurrence 1 The applicable Radioactive Material Shipment procedure has been revised to explicitly state that only authorized Health Physics personnel may request telease of radioactive material shipments. A list of the authorize? Health Physics personnel has been provided to the Operating Department.
This procedure was also revised to require Shift Engineer signature on completed shipment documentation prior to releasing Radioactive Material Shipments from site.
GET/sc1:0097T:3
= ___-_ -____ _-
S . !
'. i- I L ATTACHMENT (continngd),
I ,
Copies of the procedure change and Radiation Occurrence Report have been included in the Zion Station " Required Reading" program for the Operating and Radiation Protection departments. The Required Reading program provides documentation that cognizant personnel have been made aware of the event while also providing them with the requirements of the procedural changes.
These corrective actions served to strengthen the existing controls for authorization and final release of radioactive material shipments.
l Rate When Full Compliance Will Be Achieved:
l l Zion Station is in full compliance at this time.
l GET/sc1:00977:4
.E .
'," .s AZIACHMENT (continuedl p l 3.. Vinlation:
49 CFR:173.475 requires that prior to each shipment of any radioactive materials package, the' shipper ensure by examination or appropriate tests that certain packaging and preparation requirements are met including that: (a)
The packaging is proper for the contents to be shipped; (c) each closure device'of the packaging is properly installed, secured, and free of defects;.
(e) each special instruction for preparation of the packaging for shipment has
.been followed.
Contrary to'the above, on November 118, 1988, Zion Station shipped three packages of~ radioactively contaminated equipment / parts (2.86 millicuries) to a ,
facility in Pennsylvania, .and failed to perform the appropriate test (s) or ]
examination to ensure that packaging / preparation requirements were met prior to shipment.
This is a Severity Level IV violation (Supplement V).
Corrective Action Taken And Results Achieved Procedures in place at the time of this event should have prevented this Violation, however, personnel error on the part of the Radiation Technician-assigned to survey this shipment resulted in the shipment being released prior to appropriate testing or examination.
The Radiation Technician was. counseled to make him cognizant of the requirements which were bypassed. In addition, this event has been reviewed during a Radiation Proterf ton / Chemistry department meeting to re-emphasize the- )
need for procedural compliance. ,]
Corrective Action Taken To Prevent Recurrence Procedural revision (as discussed in response to Violation #2) has served to strengthen existing controls'for the preparation and shipment of radioactive materials.
Date When Full CompliADE.e Will Be Achieved Zion Station is in full compliance at this time.
i
-GET/sc1:0097T:5
g f: .
<d i.
ATIACIMENZ_(.sontirmedl
- 4. Violation >
49 CFR 173.425(b) and (c) require that packaged shipments and unpackaged (bulk) shipments, respectively of_ low specific activity (LSA) material consigned as exclusive use comply with the following; . . . (b)(8) the exterior or each outside package must be stenclied or otherwise marked
" Radioactive-LSA"; (b)(9) and (c)(7) specific instructions for maintenance of l exclusive use shipment controls'must be provided by the shipper to the carrier and be included with the shipping paper information.
Contrary to the above, on November 18, 1988, a shipment of LSA material consigned as exclusive use and consisting of one package of radioactively contaminated equipment / tools (2,86 millicuries) and two unpackaged but wrapped (bulk) pieces of radioactively contaminated pipe (0.01 millicuries) was shipped from Zion Station and the package was not marked " Radioactive-LSA" or marked in any other manner to indicate it contained radioactive material.
Also, specific instructions for maintenance of shipment controls were not provided to the carrier or included with shipping paper information.
This is a Severity level IV violation (Supplement V).
CDHective Action _Taken And Results Achitynd Controls in place at the time of this event should have prevented release of the shipment before it was properly marked. These same controls should have
~
also been adequate to insure that appropriate shipping documentation was provided to the driver. However, personnel error on the part of the Radiation
. Technician assigned to survey this shipment caused the shipment to be released prior to being properly marked and prior to shipping documentation being completed.
The Lead Health Physicist counseled the Radiation Protection Technician and additionally reviewed the event during a Radiation Protection / Chemistry Department Meeting to emphasize that shipping requirements be met.
In accordance with existing procedures the Zisn Station Radiation Protection department issued a Radiation Occurrence Report to document and provide corrective actions concerning this event.
These actions ensured that no additional radioactive material would be released without the proper shipping documents, t
Carrective Action Taken_Ip Prevent Recurrence The applicable Radioactive Material shipment procedure has been revised to require Shift Engineer signature on completed shipment documentation prior to releasing Radioactive Material Shipments from site. Shift Engineer signature on these shipping documents will provide assurance that applicable requirements have been met.
DAtR__Wilen rull Cop _pliancLWill._Be Achiev.ed Zion Station is in full compliance at this time.
GET/sc1:0097T 5
7, ,
4 1
APPENDIX A j CQNMONWEALTH EDISON GUIDELINES EDE SHIPMENT AND RECEIPT '
OF RADIOACTIVE MATERIALS l
(-
i t
1 i
i i
l l
I !
8 1
l 1
i 1
I j
l l i 1
i l
1 '
l l '
l
! i '
l
{
) GET/sc1:0097T 6 2
t' .
4
'. e Attachment 1 Guidelines for Shipping and Receiving Radioactive Materials A. Puroose
- The purpose of these guidelines is to provide requirements for the administrative control of radioactive material shipments by station L personnel. This also includes the required information which should be included in the annual training of personnel involved in the administrative control of radioactive shipments.
B. Scope These guidelines provides minimum requirements and information for inclusion into station procedures and programs. Each station shall incorporate and implement this information into the appropriate site specific procedures and programs.
C. - References
- 1. D. Galle and T. Maiman letter to Station Managers, dated February 15, 1989, (copy attached).
- 2. D. Galle and T. Maiman letter to Station Managers, dated February 17, 1989 (copy attached).
D. Guidance The following requirements define actions which must be completed by warehouse personnel when receiving or shipping radioactive material. If an incoming package or shipment is received by personnel other than stores / warehouse personnel, such as Maintenance, Operations, or Fuel Handling, these individuals are responsible for completing the prescribed actions. Similarly, if an outgoing package or shipment is shipped by personnel other than stores / warehouse personnel, these individuals are responsible for completing the prescribed actions.
- 1. Receiving Radioactive Material
- a. Harehouse personnel should determine if an incoming package contains radioactive material prior to official receipt of the l package. This determination should be based upon the guidelines found in Attachment 2.
- b. Inform the Radiation Protection Department of any suspicion of damage to, or breach of, the package (s). DO NOT handle the container. If the packaged is damaged, contact Radiation Protection immediately for survey and handling requirements.
3235h/1:02988
- e. . 1
\
- c. Packages containing radioactive material should not be opened i except under direct supervision of Radiation Protection.
- d. Harehouse personnel should determine if an incoming shipment is consigned as exclusive use, and if this shipment contains radioactive material. This determination should be based upon the guidelines in Attachment 2.
- e. If an incoming shipment is consigned as exclusive use, and it contains radioactive material, warehouse personnel must contact !
Radiation Protection prict to off-loading any packages. )
- f. If a common carrier shipment contains a package bearing a i Radioactive Yellow III label or radioactive LSA label (See Attachment 2), warehouse personnel must contact Radiation Protection prior to off-loading any packages. i i
- g. Warehouse personnel may off-load packages which are labeled Limited Quantity, White I, Yellow II, and Instruments and Articles, prior to the arrival of Radiation Protection.
However, Radiation Protection must be contacted immediately upon receipt of the package in order to complete a radiation survey within the required amount of time. During normal business hours, this requirement is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, while during off hours the requirement is 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
- 2. Shipping Radioactive Material
- a. Harehouse personnel shall not alter or repack the contents of any package containing radioactive material, except under the direct supervision of Radiation Protection. Harehouse personnel shall not place any additional labels on the package, or cover up any existing labels.
- b. Harehouse personnel shall obtain the appropriate shipping documentation from the Radiation Protection Department and attach it to the radioactive material package, prior to ,
shipment. If a shipment contains more than one package, the 4 documentation need only be attached to one of the packages. In addition, warehouse personnel shall provide one copy of this documentation to the driver, prior to departure.
- c. If an outgoing shipment, consigned as exclusive use, contains radioactive material, warehouse personnel must contact Radiation Protection prior ic the release of the shipment. The ;
shipment muit be surveyed prior to release. I i
- d. If an outgoing radioactive material package is labeled as l Radioactive Yellow III or Radioactive LSA, warehouse personnel i must centact Radiation Protection prior to loading.
l 3235h/2:0298B l
e .
- c, .;
- e. Harehouse personnel shall not ship radioactive material packages which violate the guidelines of individual carriers.
These guidelines are listed-in Attachment 3. However, since
' these are current guidelines,- stations should verify the guidelines on future shipments.
- 3. Irgidag -
Each station shall, at.a' minimum, incorporate the following topics and information into an annual training program for stores / warehouse
. personnel. This program should be approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in length.
A sample lesson plan is available from Nuclear Services Health
-Physics. Each station should develop site specific lesson plans utilizing this sample lesson plan.
- a. Radioactive shipping regulations -
This topic should include a listing and explanation of the various regulations which control the shipment and receipt of radioactive materials.
- b. Different types of radioactive material shipments and packages -
This topic should focus upon the identification of shipments and packages which contain radioactive material. Various sub-topics should be addressed. These are:
- 1. Radioactive Material Shipment Record (RMSR)
- 11. Radioactive Material Description e Radioactive Material e Limited Quantity e Radioactive Material, LSA e Instruments and Articles iii. Identification number
- UN2982
- UN2910
- UN2912
- UNU11 iv. Labels and Markings
- White I e Yellow II e Yellow III e Radioactive LSA e Radioactive
- v. Radioactive Placard 3235h/3:0298B l
---__- a
.c. .
.The labelling and placarding topics should specifically address the physical appearance of each label, as well as the radiological limits for packages displaying each label.
- c. Shipper guidelines -
This topic should address the guidelines of each shipper with respect to radioactive material packages (see Attachment 3).
- d. Shipment and receipt guidelines -
The guidelines described in Section D.1, Receiving Radioactive Material, and Section D.2, Shipping Radioactive Material should also be included in annual training for stores / warehouse personnel.
l 1
i 3235h/4:0298B
h- -i . I y, ,
,g +
Attachment 2- ;
1 Guidelines for Identifying Radioactive 'j Material Packages and Shipments The identification of radioactive material packages and shipments should normally be initiated prior to arrival, through the notification of Stores'and Radiation. Protection by the recipient of the radioactive material. j I
However, this may not always take place due to extenuating circumstances. . Therefore, warehouse personnel should review all shipping lj documentation upon the arrival of any package or shipment. The documentation j specifically associated with radioactive material shipments is a. Radioactive Material . Shipment Record (RMSR). The RMSR will contain a one line description ]
of the radioactive material and a universal identification number. Normally, radioactive material shipments will be identified by'one of the three following descriptions:
- 1. Radioactive Material N.0.S., UN 2982
- 11. Radioactive Material, LSA (Low Specific Activity), UN 2912 iii. Radioactive Material, Limited Quantity, UN 2910 iv. Radioactive Material, Instruments and Articles, UN 2911 In addition to the normal RMSR, all vehicles consigned as exclusive use will also have a statement instructing the driver that the vehicle is exclusive use. If this is present, and if the shipment contains radioactive material, contact Radiation Protection immediately. Do not unload or release, the vehicle until it has been surveyed by Radiation Protection.
Shipments consigned as exclusive use will also display ' Radioactive' l placards on all four sides of the vehicle. If a vehicle displays these Macards, contact Radiation Protection immediately. Howevr . the absence of thete placards does not signal that the shipment does not contain radioactive material packages.
Finally, radioactive material packages may also be required to display one of the following labels:
- 1. Radioactive White I ii. Radioactive Yellow II 111. Radioactive Yellow III iv. Radioactive LSA If a package displays these labels, contact Radiation Protection immediately. However, the absence of these labels does not signal that the package does not contain radioactive material.
3235h/5:02988
l L'q .s 7, .
Attachment 3 Carrier Guidelines for Shipment of Radioactive Material F
V I' -
Carrier Guideline Federal Express The carrier will accept any package for shipment which meets the requirements lirtsd ia 49 CFR.
Emery /Purolator The carrier will accept any package for shipment which meets the requirements listed in 49 CFR.
United Parcel Service The Carrier will only accept (UPS) packages which contain type A quantities and are labeled Radioactive White I, or a Limited Quantity package. The carrier will not accept Yellow II, Yellow III.
Consolidated Freightways. The carrier will only accept packages which are labeled White I, Yellow II, or Yellow III Roberts Express The carrier will accept any package for shipment which meets the requirements listed in 49 CFR, except for Highway Route Controlled shipments.
Yellow Freight System, Inc. The carrier will accept any package for shipment which meets the requirements listed in 49 CFR, ,
except for Highway Route Controlled !
shipments.
3235h/6:02988 1
+y? S .. 3. y 'pComm:nwMith Edison. .
"~"%'* ,- "'1 ( 72 West Adams Strzet. Chgca o' Ilknots
.\ # Address RIply to: Post OTfice Box 767 I i 1 \M : Chicago, lihnois 60690 0767 '
i: ,
E m
3 April 25, 1989
}. ,
r
.p -Mr. A. Bert Davis-
' Regional' Administrator U.S. Nuclear Regulatory Commission Region III 799' Roosevelt' Road Glen Ellyn,.IL ;60137 i
Subject:
Zion Nuclear Power Station Units 1 and ~ 2
. License Nos. DPR-39 and DPR-48 Response to Notice of Violation NRC Docket Nos. 50-295 and 50-304 References March 27, 1989- letter.from CE Norelius 47
to'JJ O'Connor Transmitting Inspection Report Nos.'
50-295/89005 and 50-304/89005
. Dear Mr. Daviss This letter. Is :in response. to an inspection performed by Messrs.
W.J. Slawinski and R.A. Paul during the periods of December 15-16; 19-21,:1988 and January 3-4, 1989 at Zion Station. The circumstances surrounding the two Transportation' Events were also discussed at an Enforcement Conference on February 16,.1989. The conclusions drawn from~the analysis of the data indicated that
.certain activities appeared to be in noncompliance with federal regulations. The response to these violations is provided in the Attachment to this letter.
Your cover letter expressed a concern about the adequacy of controls throughout the Edison' system regarding the transportation of radioactive materials. Commonwealth Edison has generated a set of guidelines to be'used at
.all of our facilit!les. ,These guidelines address the procedure to be followed by warehouse personnel who ship or receive radioactive material, and to also ensure that these personnel.are appropriately trained to correctly respond to a
-radioactive material shipment. . Guidance has also been established tc ensure that the Shift Engineer or his designate shall' verify that all appropriate documentation and surveys are complete prior to authorization of the release of the shipment. The complete guidelines are contained in Appendix A to this letter.
If you have any questions regarding this matter, please contact this office.
Very truly yours,
/ y j T . ach Nuc1 r Licensing Manager GET/sc1:0097T:1 Attachment cc: Resident Inspector-Zion
- R O rn L '/TL] & ? > o.
_ D Y ? _ ?_?_! -
h.
9' s . .
A27ACHMENT
- 1. El.qlation 10 CFR 71.5(a) prohibits transport of licensed material outside the confines of a plant or other place of use, or delivery of licensed material to a carrier for transport unless the licensee complies with 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 172.403(a) and 173.25(a)(2) require that each package and overpack, respectively of radioactive material for transportation be labeled as required with labels prescribed for the material and marked with the proper shipping name and identification number. A radioactive Yellow-II label is required on packages /overpacks with surface radiation levels greater than 0.5 mrem /hr and less than or equal to 50 mrem /hr and a transport index not exceeding 1.0.
Contrary to the above, on November 18, 1988, Zion Station shipped approximately 830 microcuries of mixed isotopes to Dresden Station in an overpack that failed to meet the prescribed marting and labeling requirements in that the overpack was not marked or labeled to indicate the contents contained radioactive material. Overpack surface and one meter radiation levels measured on receipt were 3.7 mrem /hr and 0.3 mrem /hr, respectively, and )
a transport index less than or equal to 1.0.
This is a Severity Level IV violation (Supplement V).
Corrective Action Taken And Results Achieved The Zion Station Lead Health Physicist immediately ensured that no similar
( shipments were in progress or were planned. The Lead Health Physicist also discussed the event with a Warehouse Supervisor. These actions ensured no immediate recurrence of the event.
f Corrective Actions Taken To Erevent Recurrence; l
l Prior to any similar shipments, the Lead Health Physicist conducted a review session cf radioactive materials shipment practices with all Warehouso personnel.
l
- Detailed guidelines governing the shipment and receipt of radioactive materials were provided to Warehouse personnel. These guidelines were also later incorporated into a Zion Administrative Procedure.
The applicable Zion Station Radiation Procedure was revised to require a Warehouse Supervisor's signature on common carrier shipping documents. This change ensures that the requirements contained in the Zion Administrative Procedure are followed when shipping this type of radioactive materiel.
The Zion Training Department has implemented formal recurring training for warehouse personnel on the receipt and shipmant of radioactive materials. The initial session has been completed.
Date When Full Compliance Will Be Achieved 2 Zion Station is in full compliance at this time.
GET/sc1:0097T 2
- s .
4 . .
ATTACHMENT (continued' n .i
- 2. Violation:
10 CFR 71.5(a) prohibits transport of licensed material outside the confines of a plant or other place of use, or delivery of licensed material to a carrier for transport unless the licensee complies with 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 172.200-202 require each person who offers a hazardous material for transportation to dascribe the material on the shipping paper. 49 CFR 172.203(d) describes the required additional shipping paper entries for radioactive materials.
Contrary to the above, on November 18, 1988, Zion Station offered hazardous materials consisting of radioactively contaminated equipment / parts (2.86 millicuries) to a carrier for transport without any shipping papers.
This is a Severity Level IV violation (Supplement V).
Corrective Action Taken And Results Achieved:
Personnel error on the part of the Radiation Technician assigned to survey this shipment resulted in release of this shipment in violation of shipping requirements.
Immediately following notification of this incident, an investigation was begun, shipment data was gathered and then relayed by phone to a ALARON Radiation Technician. The appropriate written records were then completed and l forwarded to ALARON, Corp.
The Lead Health Physicist counseled the Radiation Protection Technician and additionally reviewed the event during a Radiation Protection / Chemistry Department Meeting to emphasize that shipping requirements be met.
In accordance with existing procedures the Zion Station Radiation Protection I. department issued a Radiation Occurrerce Report to document and provide corrective actions concerning this event.
These actions ensured that no additional radioactive material would be released without the proper shipping documents.
Corrective Action Taken To Prevent Recurrence:
The applicable Radioactive Material Shipment procedure has been revised to explicitly state that only authorized Health Physics personnel may request {
release of radioactive material shipments. A list of the authorized Health I Physics personnel has been provided to the Operating Department.
l This procedure was also revised to require Shift Engineer signature on completed shipment documentation prior to releasing Radioactive Material Shipments from site.
l l
GET/sc1:0097T 3
$\; l '
il r 8* '
i ATTACHMENT (continued)
- . f::. f Copies'of the procedure. change and Radiation Occurrence Report have been c included..in.the Zion Station " Required Reading". program for.the Operating and Radiation Protection departments. The Required Reading program provides-documentation .that' cognizant' personnel have been made aware of the event while also providing them with the requirements of the procedural changes.
These corrective actions. served to strengthen the existing controls for-authorization'and final release of radioactive material shipments.
Date When Full Compliance Will Be Achieved:
Zion-Station!1s in. full compliance at this time.
p,
.j l
GET/sc1:0097T 4 1
- _ - - - - _ - . . _ - _ - _ _ . _ - - _ - _ . _ _ _ _ . - _ - _ .1
I 9; -
l e~" '
ATEACIRiEILT (continuzdl l 3. Violation:'
49.CFR 173.475 requires that prior to each; shipment of any radioactive 1
{
materials. package, the shipper ensure by examination or appropriate. tests that 3 certain packaging and preparation requirements are met including that (a) l The packaging is proper for the contents to be shipped; (c) each closure device of the' packaging is properly installed, secured, and free of defects; l (e) each special instruction for preparation of the packaging for sSipment has been followed.
Contrary to the above, on NovemN , 18, 1988, Zion Station shipped three packages of radioactively contaminated equipment / parts (2.86 millicuries) to a facility in Pennsylvania, and failed to perform the appropriate test (s) or examination to ensure that packaging / preparation requirements were met prior to shipment.
This is a Severity Level IV violation (Supplement V).
Corrective Action Taken And Results Achievedt Procedures in place at the time of this event should have prevented this Violation, however, personnel error on the part of the Radiation Technician assigned to survey this shipment resulted in the shipment being released prior to appropriate testing or examination.
The Radiation Technician was counseled to make him cognizant of the requirements which were bypassed. In addition, this event has been reviewed during a Radiation Protection / Chemistry department meeting to re-emphasize the need for procedural compliance.
Correcijve Action Taken To Prevent Recurrences Procedural revision (as discussed in response to Violation #2) has served to strengthen existing controls for the preparation and shipment of radioactive materials.
Date When Full Compliance Will Be Achievedt Zion Statis 1 is in full compliance at this time.
GET/scl:00977:5
4 0
ATTACHMENT (contipygdl
- i. Violations i l
49 CFR 173.425(b) and (c) require that packaged shipments and unpackaged j (bulk) shipments, respectively of low specific activity (LSA) material !
consigned as exclusive use comply with the following; . . . (b)(8) the exterior or each outside package must be stenciled or otherwise marked
" Radioactive-LSA"; (b)(9) an6 (c)(7) specific instructions for maintenance of exclusive use shipment controls must be provided by the shipper to the carrier and be included with the shipping paper information.
Contrary to the above, on November 18, 1988, a shipment of LSA material consigned as exclusive use and consisting of one package of radioactively ]
contaminated equipment / tools (2.86 mil 11 curies) and two unpackaged but wrapped (bulk) pieces of radioactively contaminated pipe (0.01 mil 11 curies) was shipped from Zion Station and the package was not marked " Radioactive-LSA" or marked in any other manner to indicate it contained radioactive material. .
Also, specific instructions for maintenance of shipment controls were not provided to the carrier or included with shipping paper information.
This is a Severity level IV violation (Supplement V),
Correctlye Action Taken And Results Achieved Controls in place at the time of this event should have prevented release of the shipment before it was properly marked. These same controls should have also been adequate to insure that appropriate shipping documentation was i provided to the driver. However, personnel error on the part of the Radiation Technician assigned to survey this shipment caused the shipment to be released prior to being properly marked and prior to shipping documentation being completed. l The Lead Health Physicist counseled the Radiation Protection Technician and additionally reviewed the event during a Radiation Protection / Chemistry Department Meeting to emphasize that shipping requirements be met.
In accordance with existing procedures the Zion Station Radiation Protection department issued a Radiation Occurrence Report to document and provide corrective actions concerning this event.
These actions ensured that no additional radioactive material would be released without the proper shipping documents.
f l C.orrective Action Taken To Prevggt Recurrence l
The applicable Radioactive Material shipment procedure has been revised to i require Shift Engineer signature on completed shipment documentation prior to releasing Radioactive Material Shipments from site. Shift Engineer signature l
on these shipping documents will provide assurance that applicable i requirements have been met.
l l
l DA.g When Full Complignp3_,W,1 1 Be Achieved l
Zion Station is in full compliance at this time.
GET/sc1:0097T 5 l
F, l!' . J:*
- i s- .
p..'.
APPENDIX A L' C. COMMONWEALTH EDISON GUIDEL1HES FOR SHIPMENT AND RECEIPT OF RADIOACTIVE MATERIALS l
i-l l
l I
l 1
l l
i GET/sc1:0097T 6 i
o .
+-
[ 4 Attachment 1 i Cuide11nes for Shipping and Receiving Radioactive Materials A. Purcose The purpose of these guidelines is to provide requirements for the administrative control of radioactive material shipments by station personnel. This also includes the required information which should be included in the annual training of personnel involved in the administrative control of radioactive shipments.
B. Scope These guidelines provides minimum requirements and information for
. inclusion'into station procedures and programs. Each station shall incorporate and implement this information into the appropriate site specific procedures and programs.
C. References
- 1. D. Galle and T. Maiman letter to Station Managers, dated February 15, 1989, (copy attached).
- 2. D. Galle and T. Maiman letter to Station Managers, dated February 17, 1989 (copy attached).
l D. Guidance The following requirements define actions which must be completed by warehouse personnel when receiving or shipping radioactive material. If an incoming package or shipment is received by personnel other than stores / warehouse personnel, such as Maintenance, Operations, or Fuel Handling, these individuals are responsible for completin! the prescribed actions. Similarly, if an outgoing package or shipment is shipped by personnel other than stores / warehouse personnel, these individuals are responsible for completing the prescribed actions.
- 1. Receiving Radioactive Material
- a. Harehouse personnel should determine if an incoming package contains radioactive material prior to official receipt of the package. This determination should be based upon the guidelines found in Attachment 2.
- b. Inform the Radiation Protection Department of any suspicion of damage to, or breach of, the package (s). _D0 NOT handle the container. If the packaged is damaged, contact Radiation Protection immediately for survey and handling requirements.
3235h/l:0298B
s . 1
- 1
,w
- c. Packages containing radioactive material should not be opened except under direct supervision of Radiation Protection.
- d. Harehouse personnel should determine if an incoming shipment is consigned as exclusive use, and if this shipment contains radioactive material. This determination should be based upon the guidelines in Attachment 2.
- e. If an incoming shipment is consigned as exclusive use, and it contains radioactive material, warehouse personnel must contact Radiation Protection prior to off-loading any packages.
- f. If a common carrier shipment contains a package bearing a Radioactive Yellow III-label or radioactive LSA label (See Attachment 2), warehouse personnel must contact Radiation Protection Drior to off-loading any packages.
- g. Harehouse personnel may off-load packages which are labeled Limited Quantity, White I, Yellow II, and Instruments and Articles, prior to the arrival of Radiation Protection.
However, Radiation Protection must be contacted _immediately upon receipt of the package in order to complete a radiation survey within the required amount of time. During normal
. business hours, this requirement is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, while during off hours the requirement is 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.
- 2. Shipping Radioactive Material
- a. Harehouse personnel shall not alter or repack the contents of any package containing radioactive material, except under the direct supervision of Radiation Protection. Harehouse personnel shall not place any additional labels on the package, or cover up any existing labels.
- b. Harehouse personnel shall obtain the appropriate shipping documentation from the Radiation Protection Department and attach it to the radioactive material package, prior to shipment. If a shipment contains more than one package, the documentation need only be attached to one of the packages. In addition, warehouse personnel shall provide one copy of this documentation to the driver, prior to departure.
- c. If an outgoing shipment, consigned as exclusive use, contains radioactive material, warehouse personnel must contact Radiation Protection prior to the release of the shipment. The shipment muit be surveyed prior to release.
l
- d. If an outgoing radioactive material package is labeled as Radioactive Yellow III or Radioactive LSA, warehouse personnel must contact Radiation Protection prior ta loading.
l 3235h/2:02988 l
- c. .
E'
- e. HarehoUse personnel-shall not ship radioactive material
- i. packages which violate.the guidelines of individual carriers.
These guidelines are listed in Attachment'3. However, since
. these are current guidelines, stations should verify the L guidelines on future shipments.
1
- 3. Iraining Each station shall, at a minimum, incorporate the following topics and information into an annual training program for stores / warehouse personnel. This program should be approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in length.
A sample lesson plan is available from Nuclear Services Health Physics. Each station should develop site specific lesson plans utilizing this sample lesson plan.
- a. Radioactive shipping. regulations -
This topic should include a listing and explanation of the various regulations which control the-shipment and receipt of radioactive materials.
- b. Different types of radioactive material shipments and packages -
This topic should focus upon the identification of shipments i and packages which contain radioactive material. Various '
sub-topics should be addressed. These are:
- 1. Radioactive Material Shipment Record (RMSR)
- 11. Radioactive Material Description
- Radioactive Material
- Limited Quantity e Radioactive Material, LSA
- Instruments and Articles 111. Identification number
- UN2982
- UN2910
- UN2912
- UN2911 iv. Labels and Markings
- White I e Yellow II e Yellow III e Radioactive LSA e Radioactive
- v. Radioactive Placard 3235h/3:02988
- fr- ..
p.... ..
.p. .
-The labelling and placarding. topics should specifically address the. physical appearance of each label, as well as the radiological limits for packages displaying each label,
- c. Shipper guidelines -
This topic should address the guidelines of each shipper with respect to radioactive material packages (see Attachment 3).
- d. Shipment and ceceipt guidelines -
The guidelines described in Section 0.1, Receiving Radioactive Material, and Section D.2, Shipping Radioactive Material should also be included in annual training for stores / warehouse personnel.
1 i
I, l
3235h/4:02988
- _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ - _. . _ i
+ .
e~ J
}
Attachment 2 Guidelines for Identifying Radioactive Material Packages and Shipments The identification of radioactive material packages and shipments should normally be initiated prior to arrival, through the notification of Stores and Radiation Protection by the recipient of the radioactive material.
However, this may not always take place due to extenuating circumstances. Therefore, warehouse personnel should review all shipping documentation upon the arrival of any package or shipment. The documentation specifically associated with radioactive material shipments is a Radioactive Material Shipment Record (RMSR). The RMSR will contain a one line description of the radioactive material and a universal identification number. Normally, radioactive material shipments will be identified by one of the three following descriptions:
- 1. Radioactive Material N.0.S., UN 2982 ii. Radioactive Material, LSA (Low Specific Activity), UN 2912 111. Radioactive Material, Limited Quantity, UN 2910 iv. Radioactive Material, Instruments and Articles, UN 2911 In addition to the normal.RMSR, all vehicles consigned as exclusive use will also have a statement instructing the driver that the vehicle is exclusive use. If this is present, and if the shipment contains radioactive material, contact Radiation Protection immediately. Do not unload or release the vehicle until it hhs been surveyed by Radiation Protection.
Shipments consigned as exclusive use will also display ' Radioactive' placards on all four sides of the vehicle. If a vehicle displays these placards, contact Radiation Protection imediately. However, the absence of these placards does not signal that the shipment does not contain radioactive material packages.
Finally, radioactive material packages may also be required to display one of the following labelt:
- 1. Radioactive White I
- 11. Radioactive Yellow II iii. Radioactive Yellow III iv. Radioactive LSA If a package displays these labels, contact Radiation Protection immediately. However, the absence of these labels does not signal that the package does not contain radioactive material.
3235h/5:0290B
l t ,, , l y y J Attachment 3 0 Carrier Guidelines for Shipment
. of Radioactive Material
' Carri er Guideline Federal Express The carrier will accept any-package for shipment which meets the requirements listed in 49 CFR.
Emery /Purolator The carrier will accept any package for shipment which meets the requirements listed in 49 CFR.
64ited Parcel Service The Carrier will only accept (UPS) packages which contain type A quantities and are labeled Radioactive White I, or a Limited Quantity package. The carrier will not accept Yellow II, Yellow III.
Consolidated Freightways The carrier will only accept packages which are labeled White I, Yellow II, or Yellow III Roberts Express The carrier will accept any package for shipment which meets the requirements listed in 49 CFR, except for Highway Route Controlled shipments. . ,
Yellow Freight System, Inc. The carrier will accept any package for shipment which meets the requirements listed in 49 CFR, except for Highway Route Controlled shipments.
323Sh/6:0298B i
_:-___________--____________-______ _ _ _ _ __ _ __ ._. ._. . _ _ _ ____a