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{{#Wiki_filter:l'indiana Michigan Power Company P.O.8ox 16631 Columbus, OH 43216 Z INDIANA NICHIGAN POWER AEP:NRC:1184A | {{#Wiki_filter:l' indiana Michigan Power Company P.O. 8ox 16631 Columbus, OH 43216 Z | ||
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 | 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) | ||
REPORT NOS.50-315/930010 (DRSS)AND 50-316/930010 (DRSS);REPLY TO A NOTICE OF VIOLATION U.S.Nuclear Regulatory | 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 | ||
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 | ==Dear Mr. Martin:== | ||
dated March 4, 1993, which forwarded a Notice of Violation that resulted from the enforcement | |||
conference | 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. | ||
conducted on March 2, 1993.The Notice of Violation attached to Mr. | identified two severity level IV violations for the Norelius'etter 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. | ||
identified | Sincerely, I | ||
two severity level IV violations | 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 | ||
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 | Attachment to AEP:NRC:1184A Response to Notice of Violation | ||
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 | Attachment to AEP:NRC:1184A Page 1 NRC Violation: | ||
APR 1 g3 | 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. | |||
Attachment | 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. | ||
to AEP:NRC:1184A | This is a Severity Level IV problem (Supplement V). | ||
Response to Notice of Violation | (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. | |||
Attachment | 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. | ||
to AEP:NRC:1184A | |||
Page 1 NRC Violation: | 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. | ||
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 | 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. | ||
requirements | 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. | ||
of the regulations | 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. | ||
appropriate | (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. | ||
to the mode of transport of the Department | 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. | ||
of Transportation (DOT)in 49 CFR Part 170-189.49 CFR 173.427(e) | 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. | ||
requires that an empty package that previously | 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. | ||
contained radioactive | This is a Severity Level XV problem (Supplement V)." | ||
materials and has been emptied comply with the requirements | |||
of 49 CFR 173.421(b) | 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. | ||
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 | (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. | ||
V).(1)Reason for Violation The licensee has concluded that the pre-shipping | 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. | ||
dose rate survey of container QG-27 was inadequate. | (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 contributing | 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. | ||
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 | 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. | ||
of detection. | |||
(2)Corrective | 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. | ||
Actions Taken and Results Achieved On January 27, 1993, the licensee informed the NRC of notification | (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. | ||
from a vendor in Oak Ridge, Tennessee, that a sea van, manifested | |||
as Radioactive | 'I ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) | ||
Material Excepted Package Empty Packaging, UN2910, had been received with dose rate surveys indicating | 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) | ||
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 | ==SUBJECT:== | ||
the apparent violation. | 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. | ||
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. | DISTRIBUTION CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE: | ||
TITLE: Environ & Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES: | |||
Attachment | RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 0 PD3-1 PD 1 1 DEANiW 1- 1 INTERNAL: AEOD/ANDERSON,R 1 1 AEOD/DSP 1 1 NMSS/SGTB 4E4 1 1 NRR/DREP/PRPB10 2 2 NRR/DRIL/RPEB10 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE D 1 1 OGC/HDS2 1 1 REG LE 02 1, 1 RES'GN3 1 1 RGN3 SS/RPB 1 1 FILE 01 1 1 RGN4 MURRAY,B 1 1 EXTERNAL: EG&G SIMPSON,F 2 2 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS: | ||
to AEP:NRC:1184A | PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 21 | ||
Page 2 (3)Preventive | |||
Actions Taken To Avoid Further Violations | indiana Michigan Power Company P.O. Box 16631'oinmbos OH 4321F | ||
Preventive | ~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) | ||
actions taken to prevent recurrence | 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 | ||
of a similar event include independent | |||
surveys of all outgoing shipments of radioactive | ==Dear Mr. Martin:== | ||
material and enhancement | |||
of procedures | 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 shipment Transportation | ||
pertaining | 'f March 2, 1993. The Notice of Violation attached to Mr. Norelius' letter identified two severity level IV violations for the an (DOT) empty box that exceeded Department contact dose rate limits and failure to of ensure the limits were met prior to shipment. Our response to the Notice of Violation is provided in the attachment to this letter. | ||
to shipment of radioactive | 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 >py< | ||
material.The policy of independent | 9304020176 930329 I | ||
surveys for all outgoing shipments of radioactive | ] | ||
material was initiated on February 1, 1993.On February 18, 1993, a policy memorandum | PDR ADQCK 050003l5 6 PDR | ||
was distributed | |||
to all radiation protection | Attachment to AEP:NRC:1184A Response to Notice of Violation | ||
department | |||
personnel outlining standards for shipment of radioactive | Attachment to AEP:NRC:1184A Page 1 NRC Violation: | ||
material.The procedure, Preparation | "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. | ||
of Radioactive | 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. | ||
Shipments, 12 THP 3150.RMC.202, was revised to include independent | 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. | ||
surveys of all outgoing radioactive | This is a Severity Level IV problem (Supplement V). | ||
material shipments, utilization | (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. | ||
of optimal instrumentation | (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. | ||
for surveys, and a checklist for"empty package" shipments. | 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. | ||
This procedure revision was completed on March 1, 1993.Training for selected radiation protection | |||
personnel on the description | 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. | ||
of the event, selection and use of optimal equipment for surveys, and proper survey methodologies | 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. | ||
will be completed by March 31, 1993.(4)Date When Full Com liance Will Be Achieved Full compliance | 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. | ||
will be achieved on March 31, 1993, with the completion | 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. | ||
of scheduled training for selected radiation protection | (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. | ||
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. | ||
B.49 CFR 173.475 requires, in part, that before each shipment of any radioactive | 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. | ||
material package, the shipper ensure by examination | 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. | ||
or appropriate | This is a Severity Level IV problem (Supplement V)." | ||
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 | 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. | ||
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 | (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. | ||
V)." | 't On January 29, 1993, a representative of the licensee arrived 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 | (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. | ||
to AEP:NRC:1184A | 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. | ||
Page 3 (1)Reason for Violation The licensee has concluded that the pre-shipping | 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. | ||
dose rate survey of container QG-27 was inadequate. | |||
The contributing | 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. | ||
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 | (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.}} | ||
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 | |||
NMSS/SGTB 4E4 NRR/DRIL/RPEB10 | |||
NUDOCS-ABSTRACT | |||
OGC/HDS2 RES'GN3 FILE 01 EXTERNAL: EG&G SIMPSON,F | |||
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 | |||
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 | |||
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 | |||
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 | |||
of scheduled training for selected radiation protection | |||
personnel. | |||
}} | |||
Latest revision as of 05:44, 29 October 2019
| 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.
identified two severity level IV violations for the Norelius'etter 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 COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 0 PD3-1 PD 1 1 DEANiW 1- 1 INTERNAL: AEOD/ANDERSON,R 1 1 AEOD/DSP 1 1 NMSS/SGTB 4E4 1 1 NRR/DREP/PRPB10 2 2 NRR/DRIL/RPEB10 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE D 1 1 OGC/HDS2 1 1 REG LE 02 1, 1 RES'GN3 1 1 RGN3 SS/RPB 1 1 FILE 01 1 1 RGN4 MURRAY,B 1 1 EXTERNAL: EG&G SIMPSON,F 2 2 NRC PDR 1 1 NSIC 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 ELIMINATEYOUR 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 shipment Transportation
'f March 2, 1993. The Notice of Violation attached to Mr. Norelius' letter identified two severity level IV violations for the an (DOT) empty box that exceeded Department contact dose rate limits and failure to of 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 >py<
9304020176 930329 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.
't On January 29, 1993, a representative of the licensee arrived 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.