ML17331A117

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

ML17331A117
Person / Time
Site:	Cook
Issue date:	03/29/1993
From:	FITZPATRICK E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	MARTIN A B 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.