ML20073A216

Responds to NRC 830209 Ltr Re Violations Noted in IE Insp Repts 50-269/82-43,50-270/82-43 & 50-287/82-43.Corrective Actions:Health Physics Procedure for Packaging & Shipping Radioactive Matl Revised

ML20073A216
Person / Time
Site:	Oconee
Issue date:	03/11/1983
From:	Tucker H DUKE POWER CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20073A166	List: ML20073A197 ML20073A216 ML20073A260
References
NUDOCS 8304110693
Download: ML20073A216 (3)

Text

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DUKE POWER GO)1PAhT -g[A, $UM O! A P.O. HOX 33180 CIIAHLOTTE, N.C. 28242 IIAL D. TUCKER l Tet.zenoxe VM R PRP.NEDE!s?

' s (70 4) 373- SM1 muu. ..""" March 11,1983 Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30303

Subject:

Oconee Nuclear Station IE Inspection Report 50-269/82-43 50-270/82-43 50-287/82-43

Dear Sir:

With regard to Mr. H. C. Dance's letter of February 9, 1983 which transmitted the subject inspection report, Duke Power Company does not consider the informa-tion contained therein to be proprietary.

Please find the attached response to the cited item of noncompliance.

I declare under penalty of perjury that the statements set forth herein are true and correct to the best of my knowledge, executed on March 8, 1983.

Very truly yours, C

W

/Hal B. Tucker -

PFG/php Attachment 83041i0693 B30325 PDR ADDCK 05000269 G PDR J

as . s Violation 10 CFR 71.5(a) requires a licensee, who transports any licensed material outside the confines of his plant or other place of use, or delivers any licensed material for transport, except where such transport is subject to the regulations of the U. S. Postal Service, to comply with the applicable requirements of the Department of Transportation regulations presented in 49 CFR Parts 170 through 189 insofar as such regulations relate to the packaging of byproduct, source, or special nuclear material, marking and labeling of the packages, loading and storage of packages, placarding of the transportation vehicle, monitoring requirements, and accident reporting.

49 CFR 173.393(n) (9) requires that prior to each shipment of any package, the shipper shall ensure by examination or appropriate test that external radiation and contamination levels are within the allowable limits.

Contrary to the above, on November 22, 1982, the licensee failed to perform an appropriate test in that a sufficient number of tests (radiation surveys) were not made to detect representative contamination levels on a radioactive waste shipment delivered to a carrier for transport. On November 23, 1982, after arrival at Chem-Nuclear Systems, Inc. (CNSI), Barnwell, SC, burial facility, radiation surveys performed by CNSI and the transport vehicle well in excess of those detected by the licensee.

This is a Severity Level IV Violation (Supplement V).

Response

1) Admission or denial of the alleged violation:

Duke' Power Company has never intended (and does not intend in the future) to ship any removable contamination in excess of regulatory limits to the Barnwell burrial site, either on the shipping package or on the transport vehicle. Oconee procedures have been designed to perform a statistical, representative survey of the package and the transport vehicle to determine if such contamination is present. This program has been successfully used for over 1000 waste shipments in which both federal and state criteria were met, and no significant removable surface contamination was detected

upon arrival at the burial facility. The cited example is the only case in which significant removable contamination was found on the transport vehicle upon its arrival at the burial facility. The station program was apparently unsuccessful in locating this contamination. If the interpre- ,

tation of the federal regulations is that an adequate survey of the l transport vehicle along with the shipping package was required and not performed in this case, then the violation is valid.

I

2) Reasons for the violation: i Oconee personnel have used a " representative sample" smear technique as ,

the primary method for ascessment of removable contamination on waste I shipments such as this. Smears were taken at 1ccations on the shipping

i. cask and transport vehicle where the probability of contamination is i

highest. No events, such as spillage or leakage, were noticed during the handling of this waste shipment which would have led survey personnel to specifically smear the area later found to be contaminated on the vehicle.

so- .,

The contaminated area apparently was so small that the representative areas smeared did not detect it.

3) Corrective actions taken and results:

The station Health Physics procedure for Packaging and Shipment of Radioactive Material has been revised to conform to that used by the State of South Carolina to assess contamination. This procedure is used during the exit survey for each radioactive waste shipment.

4) Corrective actions to be taken to avoid further violations:

No further corrective actions are considered necessary.

5) Date when full compliance will be achieved:

All corrective actions have been completed.

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