ML17331A117

Responds to NRC 930304 Ltr Re Violations Noted in Insp Repts 50-315/93-10 & 50-316/93-10.Corrective Actions:Training for Selected Radiation Protection Personnel on Event & Use of Optimal Equipment for Surveys Will Be Completed by 930331

ML17331A117
Person / Time
Site:	Cook
Issue date:	03/29/1993
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Martin A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:1184A, NUDOCS 9304020176
Download: ML17331A117 (18)

Text

l'indiana Michigan Power Company P.O.8ox 16631 Columbus, OH 43216 Z INDIANA NICHIGAN POWER AEP:NRC:1184A Donald C.Cook Nuclear Plant Units 1 and 2 Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 NRC INSPECTION REPORT NOS.50-315/930010 (DRSS)AND 50-316/930010 (DRSS);REPLY TO A NOTICE OF VIOLATION U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20005 ATTN: A.BE Martin March 29, 1993

Dear Mr.Martin:

This letter is in response to Mr.Charles E.Norelius'etter dated March 4, 1993, which forwarded a Notice of Violation that resulted from the enforcement conference conducted on March 2, 1993.The Notice of Violation attached to Mr.Norelius'etter identified two severity level IV violations for the shipment of an empty box that exceeded Department of Transportation (DOT)-contact dose rate limits and failure to ensure the limits were met prior to shipment.Our response to the Notice of Violation is provided in the attachment to this letter.Sincerely, I E.E.Fi.tzp rick Vice President eg Attachment CC: A.A.Blind-Bridgman J.R.Padgett G.Charnoff NRC Resident Inspector-Bridgman NFEM Section Chief A.B.Davis=Region--III APR 1 g3

Attachment to AEP:NRC:1184A Response to Notice of Violation

Attachment to AEP:NRC:1184A Page 1 NRC Violation:

A."10 CFR 71.5(a)requires that licensees, who transport licensed material outside the confines of their plants or deliver licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)in 49 CFR Part 170-189.49 CFR 173.427(e) requires that an empty package that previously contained radioactive materials and has been emptied comply with the requirements of 49 CFR 173.421(b) that states that radiation levels at any point on the external surface of the package do not exceed 0.5 millirem per hour.Contrary to the above, on January 26, 1993, an empty package was delivered to a vendor in Oak Ridge, Tennessee with external radiation levels of 180 millirem per hour over a small area of the package.This is a Severity Level IV problem (Supplement V).(1)Reason for Violation The licensee has concluded that the pre-shipping dose rate survey of container QG-27 was inadequate.

The contributing causes of this violation were that the dose rate meter used for the survey was not optimally suited for surveying an empty container and the location of the small, localized source increased the difficulty of detection.

(2)Corrective Actions Taken and Results Achieved On January 27, 1993, the licensee informed the NRC of notification from a vendor in Oak Ridge, Tennessee, that a sea van, manifested as Radioactive Material Excepted Package Empty Packaging, UN2910, had been received with dose rate surveys indicating external radiation levels that exceeded the 0.5 millirem per hour allowable limit.On January 29, 1993, a representative of the licensee arrived at the vendor's facility to investigate the apparent violation.

The vendor had removed, measured, and disposed of the particle the previous day.Consequently, the licensee was unable to verify the dose rates on the sea van.

Attachment to AEP:NRC:1184A Page 2 (3)Preventive Actions Taken To Avoid Further Violations Preventive actions taken to prevent recurrence of a similar event include independent surveys of all outgoing shipments of radioactive material and enhancement of procedures pertaining to shipment of radioactive material.The policy of independent surveys for all outgoing shipments of radioactive material was initiated on February 1, 1993.On February 18, 1993, a policy memorandum was distributed to all radiation protection department personnel outlining standards for shipment of radioactive material.The procedure, Preparation of Radioactive Shipments, 12 THP 3150.RMC.202, was revised to include independent surveys of all outgoing radioactive material shipments, utilization of optimal instrumentation for surveys, and a checklist for"empty package" shipments.

This procedure revision was completed on March 1, 1993.Training for selected radiation protection personnel on the description of the event, selection and use of optimal equipment for surveys, and proper survey methodologies will be completed by March 31, 1993.(4)Date When Full Com liance Will Be Achieved Full compliance will be achieved on March 31, 1993, with the completion of scheduled training for selected radiation protection personnel.

B.49 CFR 173.475 requires, in part, that before each shipment of any radioactive material package, the shipper ensure by examination or appropriate tests, that the external radiation levels are within allowable limits.Contrary to the above, on January 26, 1993, an empty package was shipped without the shipper ensuring by appropriate surveys that external radiation levels were within applicable limits.Specifically, the departure survey failed to detect a radiation level of 180 millirem per hour, which exceeded the 0.5 millirem per hour allowable limit.This is a Severity Level XV problem (Supplement V)."

Attachment to AEP:NRC:1184A Page 3 (1)Reason for Violation The licensee has concluded that the pre-shipping dose rate survey of container QG-27 was inadequate.

The contributing causes of this violation were that the dose rate meter used for the survey was not optimally suited for surveying an empty container and the location of the small, localized source increased the difficulty of detection.

(2)Corrective Actions Taken and Results Achieved On January 27, 1993, the licensee informed the NRC of notification from a vendor in Oak Ridge, Tennessee, that a sea van, manifested as Radioactive Material Excepted Package Empty Packaging, UN2910, had been received with dose rate surveys indicating external radiation levels that exceeded the 0.5 millirem per hour allowable limit.On January 29, 1993, a representative of the licensee arrived at the vendor's facility to investigate the apparent violation.

The vendor had removed, measured, and disposed of the particle the prevt.ous day.Consequently, the licensee was unable to verify the dose rates on the sea van.(3)Preventive Actions Taken To Avoid Further Violations Preventive actions taken to prevent recurrence of a similar event include independent surveys of all outgoing shipments of radioactive material and enhancement of procedures pertaining to shipment of radioactive material.The policy of independent surveys for all outgoing shipments of radioactive material was initiated on February 1, 1993.On February 18, 1993, a policy memorandum was distributed to all radiation protection department personnel outlining standards for shipment of radioactive material.The procedure, Preparation of Radioactive Shipments, 12 THP 3150.RMC.202, was revised to include independent surveys of all outgoing radioactive material shipments, utilization of optimal instrumentati.on for surveys, and a checklist for"empty package" shipments.

This procedure revision was completed on March 1, 1993.

Attachment to AEP:NRC:1184A Page 4 Training for selected radiation protection personnel on the description of the event, selection and use of optimal equipment for surveys, and proper survey methodologies will be completed by March 31, 1993.(4)Date When Full Com lienee Will Be Achieved Full compliance will be acnieved on March 31, 1993, with tne completion of scheduled training for selected radiation protection personnel.

'I ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION NBR:9304020176 DOC.DATE: 93/03/29 NOTARIZED:

NO DOCKET FACIL:5G-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.

Indiana Michigan Power Co.(formerly Indiana&Michigan Ele RECIP.NAME

'ECiPIENT AFFILIATION MARTIN,A.B.

Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 930304 ltr re violations noted in insp repts 50-315/93-10

&50-316/93-10.Corrective actions:training for selected radiation protection personnel on event&use of optimal equipment for surveys will be completed by 930331.DISTRIBUTION CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE: TITLE: Environ&Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES: RECIPIENT ID CODE/NAME PD3-1 LA DEANiW INTERNAL: AEOD/ANDERSON,R NMSS/SGTB 4E4 NRR/DRIL/RPEB10 NUDOCS-ABSTRACT OGC/HDS2 RES'GN3 FILE 01 EXTERNAL: EG&G SIMPSON,F NSIC COPIES LTTR ENCL 1 0 1-1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 RECIPIENT ID CODE/NAME PD3-1 PD AEOD/DSP NRR/DREP/PRPB10 NRR/PMAS/ILRB12 OE D REG LE 02 RGN3 SS/RPB RGN4 MURRAY,B NRC PDR COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1, 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 21

indiana Michigan Power Company P.O.Box 16631'oinmbos OH 4321F~R-INDIANA NICHIGAM POWM AEP'NRO'1184A Donald C.Cook Nuclear Plant Units 1 and 2 Docket,.Nos.

50-315 and 50-316 License Nos.DPR-58 and DPR-74 NRC INSPECTION REPORT NOS.50-315/930010 (DRSS)AND 50-316/930010 (DRSS);REPLY TO A NOTICE OF VIOLATION U.S.Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.20005 ATTN: A.B.Martin March 29, 1993

Dear Mr.Martin:

This letter is in response to Mr.Charles E.Norelius'etter dated March 4, 1993, which forwarded a Notice of Violation that resulted from the enforcement conference, conducted on March 2, 1993.The Notice of Violation attached to Mr.Norelius'letter identified two severity level IV violations for the shipment'f an empty box that exceeded Department of Transportation (DOT)contact dose rate limits and failure to ensure the limits were met prior to shipment.Our response to the Notice of Violation is provided in the attachment to this letter.Sincerely, E.E.Fitzp rick Vice President eg Attachment CC: A.A.Blind-Bridgman J.R.Padgett G.Charnoff NRC Resident Inspector-Bridgman NFEM Section Chief A.B.Davis-Region III 020034 9304020176 930329 PDR ADQCK 050003l5 6 PDR>py<I]

Attachment to AEP:NRC:1184A Response to Notice of Violation Attachment to AEP:NRC:1184A Page 1 NRC Violation:

"10 CFR 71.5(a)requires that licensees, who transport licensed material outside the confines of their plants or deliver licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)in 49 CFR Part 170-189.49 CFR 173.427(e) requires that an empty package that previously contained radioactive materials and has been emptied comply with the requirements of 49 CFR 173.421(b) that states that radiation levels at any point on the external surface of the package do not exceed 0.5 millirem per hour.Contrary to the above, on January 26, 1993, an empty package was delivered to a vendor in Oak Ridge, Tennessee with external radiation levels of 180 millirem per hour over a small area of the package.This is a Severity Level IV problem (Supplement V).(1)Reason for Violation The licensee has concluded that the pre-shipping dose rate survey of container QG-27 was inadequate.

The contributing causes of this violation were that the dose rate meter used for the survey was not optimally suited for surveying an empty container and the location of the small,, localized source increased the difficulty of detection.

(2)Corrective Actions Taken and Results Achieved On January 27, 1993, the licensee informed the NRC of notification from a vendor in Oak Ridge, Tennessee, that a sea van, manifested as Radioactive Material Excepted Package Empty Packaging, UN2910, had been received with dose rate surveys indicating external radiation levels that exceeded the 0.5 millirem per hour allowable limit.On January 29, 1993, a representative of the licensee arrived at the vendor's facility to investigate the apparent violation.

The vendor had removed, measured, and disposed of the particle the previous day.Consequently, the licensee was unable to verify the dose rates on the sea van.

Attachment to AEP:NRC:1184A Page 2 (3)Preventive Actions Taken To Avoid Further Violations Preventive actions taken to prevent recurrence of a similar event include independent surveys of all outgoing shipments of radioactive material and enhancement of procedures pertaining to shiprpent of radioactive material.The policy of independent surveys for all outgoing shipments of radioactive material was initiated on February 1, 1993.On February 18, 1993, a policy memorandum was distributed to all radiation protection department personnel outlining standards for shipment of radioactive material.The procedure, Preparation of Radioactive Shipments, 12 THP 3150.RMC.202, was revised to include independent surveys of all outgoing radioactive material shipments, utilization of optimal instrumentation for surveys, and a checklist for"empty package" shipments.

This procedure revision was completed on March 1, 1993.Training for selected radiation protection personnel on the description of the event, selection and use of optimal equipment for surveys, and proper survey methodologies will be completed by March 31, 1993.(4)Date When Full Com liance Will Be Achieved Full compliance will be achieved on March 31, 1993, with the completion of scheduled training for selected radiation protection personnel.

49 CFR 173.475 requires, in part, that before each shipment of any radioactive material package, the shipper ensure by examination or appropriate tests, that the external radiation levels are within allowable limits.Contrary to the above, on January 26, 1993,, an empty package was shipped without the shipper ensuring by appropriate surveys that external radiation levels were within applicable limits.Specifically, the departure survey failed to detect a radiation level of 180 millirem per hour, which exceeded the 0.5 millirem per hour allowable limit.This is a Severity Level IV problem (Supplement V)."

Attachment to AEP:NRC:1184A Page 3 (1)Reason for Violation The licensee has concluded that the pre-shipping dose rate survey of container QG-27 was inadequate.

The contributing causes of this violation were that the dose rate meter used for the survey was not optimally suited for surveying an empty container and the location of the small, localized source increased the difficulty of detection.

(2)Corrective Actions Taken and Results Achieved On January 27, 1993, the licensee informed the NRC of notification from a vendor in Oak Ridge, Tennessee, that a sea van, manifested as Radioactive Material Excepted Package Empty Packaging, UN2910, had been received with dose rate surveys indicating external radiation levels that exceeded the 0.5 millirem per hour allowable limit.On January 29, 1993, a representative of the licensee arrived't the vendor's facility to investigate the apparent violation.

The vendor had removed, measured, and disposed of the particle the previous day.Consequently, the licensee was unable to verify the dose rates on the sea van.(3)Preventive Actions Taken To Avoid Further Violations Preventive actions taken to prevent recurrence of a similar event include independent surveys of all outgoing shipments of radioactive material and enhancement of procedures pertaining to shipment of radioactive material.The policy of independent surveys for all outgoing shipments of radioactive material was initiated on February 1, 1993.On February 18, 1993, a policy memorandum was distributed to all radiation protection department personnel outlining standards for shipment of radioactive material.The procedure, Preparation of Radioactive Shipments, 12 THP 3150,RMC.202, was revised to include independent surveys of all outgoing radioactive material shipments, utilization of optimal instrumentation for surveys, and a checklist for"empty package" shipments.

This procedure revision was completed on March 1, 1993.

Attachment to AEP:NRC:1184A Page 4 Training for selected radiation protection personnel on the description of the event, selection and use of optimal equipment for surveys, and proper survey methodologies will be completed by March<<31, 1993.(4)Date Vhen Full Com liance Vill Be Achieved Full compliance will be achieved on March 31, 1993, with the completion of scheduled training for selected radiation protection personnel.