ML20215N109

Responds to NRC Re Violations Noted in Insp Rept 50-298/86-19.Corrective Actions:Specific Procedural Guidance Re Storage & Release of Matl Radiologically Surveyed Provided to Station Personnel

ML20215N109
Person / Time
Site:	Cooper
Issue date:	10/07/1986
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
CNSS866027, NUDOCS 8611040284
Download: ML20215N109 (5)

Text

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CNSS866027 . - . - - . - - - . - ,

October 7, 1986 ." N i

b YA..  ; i s d OCI 2 21986 l 4 Mr. R. D. Martin .

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

Nebraska Public Power District Response to IE Inspection Report No. 50-298/86-19

Dear Mr. Martin:

This letter is written in response to your letter dated September 12, 1986, transmitting Inspection Report No. 50-298/86-19. Therein you indicated that certain of our activities were in violation of NRC requirements.

Following are the statements of the violation and our responses in accordance with 10CFR2.201:

1. Statement of Violation Failure to Perform Adequate Surveys 10 CFR 71.5(a) requires, in part, that each licensee who delivers licensed material to a carrier for transport shall comply with the applicable requirements of Department of Transportation (DOT) regulations 49 CFR Parts 170 through 189. 49 CFR 173.475(1) requires, in part, that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests that external radiation and contamination levels are within the allowable limits specified in this subchapter " Hazardous Materials Regulations".

Contrary to the above, the licensee failed on April 10, 1985, to perform adequate surveys of a radioactive contaminated sandblaster prior to shipping the equipment to an offsite facility. At the offsite facility surveys indicated smearable contamination levels of 3,000 to 6,000 disintegrations per minute per 100 square centimeters.

This is a Severity Level IV violation. (Supplement V) (298/8619-01) 8611040284 861007 PDR ADOCK 05000290 g

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-, >(p R. D. M:rtin Octobar.7,.1986 Page 2 Reason For Violation This violation was the result of a failure to adequately control material from the time,that it had been radiologically surveyed for unrestricted release off.-

site until-the time that the material was actually released off site.

The sandblaster was surveyed and tagged for both unrestricted use and release off site seven (7). days prior to the time it actually left the site (April 17,1985) . During this seven day period, the sandblaster was apparently used-for work involving radioactive materials. Following this use, the sandblaster was released off site without further radiological surveys being conducted.

Corrective Steps Which Have Been Taken And The Results Achieved Cooper Nuclear Station Health Physics Procedure 9.2.4, " Surveying Materials For Release Off-Site",.was developed and approved on August 8, 1986, after a thorough station management review of this incident. This procedure outlines the time period allowed between the performance of radiological surveys for material to be released off site and the time when the material is actually released off site for unrestricted use. In addition, this procedure designates storage locations to provide control over materials that have been radiologically surveyed for unrestricted use, but have.not yet been directly released off site.

As a result of these corrective steps, station personnel are now provided with specific procedural guidance regarding the storage and release of material radiologically surveyed for unrestricted use.

Corrective Steps Which Will Be Taken To Avoid Further Violations It is felt that the additional controls delineated in Station Procedure 9.2.4 will preclude a recurrence of a similar event.

Date When Full Compliance Will Be Achieved As previously. stated, Cooper Nuclear Station Health Physics Procedure 9.2.4,

Surveying Materials For Release Off-Site", was approved on August 8,1986.

Full compliance was achieved on this date.

2. Statement Of Violation Failure to Identify Shipment of Radioactive Materials 10 CFR 71.5(a) requires, in part, that each licensee who delivers licensed material.to a carrier for transport shall comply with the applicable requirements of DOT regulations 49 CFR Parts 170 through 189.

49 CFR 171.2(a)- requires, in part, "No person may offer . . . hazardous material for transportation in commerce unless that material is properly classed, described, packaged, marked, labeled, and in condition for-shipment as required or authorized by this subchapter . . .". 49 CFR 173.421(d) requires, in part, for the shipment of limited quantities of

. t %,. . D. MIrtin Octchsr 7, 1986 Page 3

, radioactive materials, that "the outside of the packaging itself bears the marking 'RADI0 ACTIVE'".

, Contrary to the above, a sandblaster containing radioactive material (about 16 microcuries of contaminated aluminum oxide grit) was shipped to an'offsite facility on April 17, 1985, without having been identified by label or marking as being radioactive.

This is a Severity Level IV violation. (Supplement V) (298/8619-02)

Reason For Violation As previously stated, the failure to adequately control material from the time that it had.been radiologically surveyed for unrestricted release off site t until the time when the material was actually released off site was the cause of this violation. The sandbla' ster was surveyed and tagged for unrestricted use and release off site seven (7) days prior.to its actual release

(April 17, 1985). During this seven day period, the. sandblaster was

apparently used for work involving radioactive materials. Following this use, l the sandblaster was released off site without further radiological surveys being conducted. Failure to perform these surveys caused the' sandblaster to be shipped without being identified by label or marked as being radioactive.

Corrective Steps Which Have Been Taken And The Results Achieved Cooper. Nuclear Station Health Physics Procedure 9.2.4, " Surveying Materials for Release Off-Site", was developed and approved on August 8,1986, af ter a thorough station management review of this incident. The procedure outlines the requirements for controlling materials that have been radiologically surveyed for unrestricted use, but has not yet been directly released off site. This specific procedure criteria will provide station personnel instruction as to the disposition of releaseable materials such that radioactive materials will not be released for unrestricted use and, thus, prevent the mislabeling of these materials. By providing station personnel with this specific procedural guidance,'similar events of this type will be precluded.

Corrective Steps Which Will Be Taken To Avoid Further Violations The additional criteria and controls delineated in Station Procedure 9.2.4 will prevent the recurrence of a similar event and avoid any further violations in this area.

Date When Full Compliance Will Be Achieved Cooper Nuclear Station Health Physics Procedure 9.2.4, " Surveying Materials For Release'Off-Site", which outlines the requirements for release for materials off site and provides controls over materials intended for eventual off site release, was approved on August 8, 1986. ' Full compliance was achieved on this date.

R. D M;rtin Octcbsr 7,-1986 Page 4

3. Statement of Violation Unauthorized Transfer of Licensed Materials 10 CFR 30.41(b)(5) prohibits the ~ transfer of byproduct material except to persons authorized to receive such byproduct material under terms of a specific license or a general license or their equivalent issued by the Atomic Energy Commission, the Commission, or an Agreement State.

Contrary to the above, on April 17, 1985, the licensee transferred approximately 170 pounds of aluminum oxide containing 16 microcuries of cobalt-60 in a sandblaster to a vendor who was not authorized to receive byproduct material in accordance with 10 CFR Part 30.41(b)(5).

This is a Severity Level IV violation. (Supplement IV) (298/8619-03)

Reason For Violation As previously stated, the failure to adequately control material from the time that it had been radiologically surveyed for unrestricted release off site until the time when the material was actually released off site led-to this violation. The sandblaster was surveyed and tagged for unrestricted use and release off site seven (7) days prior to its actual release (April 17, 1985).

During this seven day period, the sandblaster was apparently used for work involving radioactive materials. Following this use, the sandblaster was released off site without further. radiological surveys being conducted.

Failure to perform these surveys resulted in the radiologically contaminated sandblaster being.sent to a vendor which was not authorized to receive byproduct material in accordance with 10 CFR Part 30.41(b)(5).

Corrective Steps Which Have Been Taken And The Results Achieved After a thorough review of this incident, Cooper Nuclear Station Health Physics Procedure 9.2.4, " Surveying Materials For Release Off-Site", was l approved on August 8, 1986. This procedure outlines the requirements for controlling materials that have been radiologically surveyed for unrestricted use, but have not yet been directly released of f site. Specific procedural

instructions regarding the control of material surveyed for unrestricted release off site will prevent the release of radioactive material for unrestricted use and, thus, prevent these materials from being shipped to unauthorized receivers.

Corrective Steps Which Will Be Taken To Avoid Further Violations It is felt that the additional criteria and controls added to Station Procedure 9.2.4 will prevent the recurrence of a similar event and avoid further violations in this area.

4

, '. . t R. D. M rtin October 7, 1986 Page 5 Date When Full Compliance Will Be Achieved Cooper Nuclear Station Health Physics Procedure 9.2.'4, " Surveying Materials For Release Off-Site", which outlines the requirements for release of material off site and provides controls over materials intended for eventual off si*e release was approved on August 8, 1986. Full compliance was achieved on this date.

If'you have any questions regarding this response. please contact me or G. R. Horn at the site.

Sincerely, M

J. . Pilant Technical Staff Manager Nuclear Power Group JMP:RLB:JVS:ya