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| issue date = 03/29/1993 | | issue date = 03/29/1993 | ||
| title = 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 | | title = 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 | ||
| author name = | | author name = Fitzpatrick E | ||
| author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG | | author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG | ||
| addressee name = | | addressee name = Martin A | ||
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) | | addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) | ||
| docket = 05000315, 05000316 | | docket = 05000315, 05000316 |
Revision as of 15:47, 18 June 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) | |
See also: IR 05000315/1993010
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.