ML20126K654

Responds to NRC 921203 Ltr Re Violations Noted in Insp Rept 50-483/92-25.Corrective Actions:Special Training Session Presented to All Storeroom Personnel Working on Receiving Dock & Procedure Re Control of Radioactive Sources Revised

ML20126K654
Person / Time
Site:	Callaway
Issue date:	01/04/1993
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-2740, NUDOCS 9301070208
Download: ML20126K654 (3)

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IL,LECTRIC wu 33 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 ULNRC -2740 Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/92025 CALLAWAY PLANT This responds to C. D. Pederson's letter dated December 3,1992, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/92025. An extension of the response due date to January 13,1993 was discussed with NRC Inspector Dave Nelson on December 16, 1992. The extension was granted due to Union Electric's receipt of the inspection Report on December 14,1992 and the scheduled holidays and vacations. Our response to the violation is presented below.

None of the material in the response is considered proprietary by Union Electric Company.

Sintement of Violatimi During an NRC inspection conducted on November 2 through 6,1992, a violation of NRC requirements was identified in accordance with the " General Statement of Policy-and Procedure for NRC Enforcement Actions, "10CFR2, Appendix C, the violation is .

listed below:

Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained. Callaway licalth Physics Technical Procedures 11TP-ZZ-02002 and liTP-ZZ-02004 require that upon receipt of a package containing radioactive material,' including the receipt of radioactive sources, licalth Physics shall perform a survey within three hours or within eighteen hours if received after normal '

working hours.

Contrary to the above, on July 22,1992 and Septembu 9,1992c the licensee failed to survey a package containing radioactive materia' nithin three or cighteen hours of receipt.

This is a Severity Level.V violation (Supplement IV),

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. s UI,NRC-2740 I Page 2 of 3 Rntimi for Ihe Violathu l

The occurrence of July 22,1992 was caused by miscommunication between Storeroom anc' Radwaste personnel and failure of Union Electric to provide adequate procedural guidance to ensure notifications reach the appropriate personnel. A shielded shipping container used for sending radioactive samples to an o.'f-site laboratory was returned to the site following sample analysis. Storeroom personnel notined the Radwaste Supervisor that the container had been returned and in doing so, assumed the requirement ofIITP-ZZ-02002 to " Notify Health Physics" had been satisfied, The  :

Radwaste Supervisor assumed the container was being returned empty and did not recognize the call from the storeroom as a notification for receipt of radioactive --

material. Not realizing the samples had been returned along with the shipping container, the Radwaste Supervisor directed Storeroom personnel to deliver the container to the Radwaste Building. The container was discovered by Health Physics personnel during routine surveys on July 27,1992.

The occurrence of September 9,1992 was caused by a provision in Union Electric's procedure llTP-ZZ 02002, Receipt and Shipment of Radioactive Material, which requires surveys of all radioactive material regardless of quantity. Although we provide instructions to vendors that all packaged radioactive material be externally ,

identined, the regulatory requirements of 10CFR20.205 allow limited quantitles to be

- shipped without such identification. If a vendor does not provide labeling per our instructions, there is no mechanism to trigger arrival notification. When the additional ,

labeling is not provided, the material is not identified as radioactive and initial notification of Health Physics by storeroom personnel does not occur, resulting in violation of procedural requirements to perform receipt surveys on all radioactive material within three or eighteen hours of receipt.

Carmtive Steps that have been_laken and result 12chieved:

1. A special training session was presented to all Storeroom personnel who work on the receiving dock. This training covered receipt survey requirements of '

radioactive material, radioactive material markings and labels, and a review of -

SOS 92-1579.

2. HTP ZZ-02002, Receipt and Shipment of Radioactive Material, has been revised i to remove mandatory receipt surveys for quantities of radioactive material below the requirements of 10CFR20.205.

3. HTP-ZZ-02004, Control of Radioactive Sources, has been revised to delete initial receipt survey requirements. Receipt surveys for all radioactive material, f

including radioactive sources, are now addressed only in HTP-ZZ-02002, Receipt and Shipment of Radioactive Material.

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4. WSP-ZZ-00003, Storeroom Material Receiving has been revised to direct storeroom personnel to provide radioactive material receipt notification to a -

specific individual in the 11ealth Physics Department (IIcalth Physics Shift Supervisor) instead of previous wording which simply stated, " Notify licalth Physics."

Corrective step 3_Ilmt will be taken to avoid furiber slolallonu The actions listed above should be adequate to prevent recurrence of the cited procedural violations.

Date when full compilnnce ulli be achieved:

il Full compliance was achieved by January 4,1993.

, if you have any questions regarding this response, or if additional information is required, please let me know.

Very truly yours,

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y)  : wl Donald F. Schnell-o DFS/skn ec: A. BJDavis - Regional Administrator, USNRC Region til L N. Jackiw - Chief, Reactor Projects Section 3C, USNRC Region 111 C. D. Pederson, Chief, Reactor Support Programs Branch, USNRC Region III.-

l L. R. Wharton _USNRC Licensing Project Manager (2 copies)

USNRC Document Control Desk (Original)-

Manager - Electric Department, Missouri Public Service Commission B. L. Bartlett - USNRC Senior Resident Inspector Shaw, Pittman, Potts, and Trowbridge -

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DEC 151932 American College of Nuclear Physicians, ATIN: Robert J. Lull, M.D.

1101 Connecticut Avenue, N.W.

Suite 700 Washington, D.C. 20036

Dear Dr. Lull:

Thank you for submitting the name of Mr. Terry frazee in nomination for membership on the Advisory Committee on the Medical Uses of Isotopes.

We will consider your nominations along with those of other applicants received in response to our Federal Reaister notice of October 16, 1992.

If you have any questions please call Sally Merchant of the staff at (301) 504-2637.

Sincerely, Larry W. Camper, Section leader Medical and Academic Section ~

Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards 06013u Distribution SMerchant IMNS Central files *NRC.FilexCenter a IMAB r/f JEGlenn LCamper 0FC IMAB IMA.8/) M NAME SMerchhn$ Ldkkr

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