IR 05000245/1990003
| ML20012A367 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/22/1990 |
| From: | Bores R, Joseph Furia NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012A361 | List: |
| References | |
| 50-245-90-03-EC, 50-245-90-3-EC, 50-336-90-04, 50-336-90-4, 50-423-90-03, 50-423-90-3, NUDOCS 9003090326 | |
| Download: ML20012A367 (20) | |
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Enclosure 2'
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NUCLEAR RBIHA'ICRY 03 MISSION
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REGICH I
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50-245/90-03
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50-336/90-04
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Report Nos. 50-423/90-03
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50-245
50-336
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Docket Hos. 50-423 j
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IFR-21
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DFR-65
License Nos. NPF-49 -
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-Licensee: Northeast Nuclear Energy Ctmpany i
F.-~o. sox 270 Hartford, Cuisechicut 06141-0270
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Facility Name: Millstone Units 1, 2 &-3
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Meeting At: NRC Region I, King of Pn:ssia, Pennsylvania-c
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p Meeting conducted:' Fetruary 20, 1990
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,NMew Jh 2/fo L:n Prepared By:
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~1a,VRadiation Specialist, Effluents Radiation date
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g. Bores, Chief, ERPS,= Facilities Radiological Safety date,
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and Safeguards Brandl l-Meeting Sununary:: :Enforcenent Conference at NRC Region'I, Kirs of Prussia,-
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Pennsylvania,.on February 20,-1990, to discuss the findings of NRC Combined-Inspection Report Nos.- 50-245/90-03; 50-336/90-04; 50-423 dimenamad related to the shinaant of an underwater shear c/90-03. '1he topic-
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utter (USC) to the
t Duane Arnold Energy Center, Palo, Iowa.
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o 3'Ihe meeting was' attended by NRC and licensee mank==uit and lasted for f
approximately ninety minutes.
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DETATIS 1.
Participants 1.1 ~ Northeast Nuclear Energy Ompany P. - Blasioli,irector, Millstone Unit Services Supervisor, Nuclear Licensing H. Ha
,. D C. Pa
, Manager, Health Ihysics Support W. Fand = g,irector, Millstone StationVice President, Nuclear Operations S.~ ear *, D S.'Turowski, Radioactive Materials Haniling Supervisor 1.2 NRC Pe.umansl
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R. Bellamy, Olief, Facilities Radiological Safety and Safeguards Branch,' RI M. Boyle, Millstone Project Manager, NRR
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D. Dempsey, Resident Inspector, Millstone J. Furia, Radiation P ialist, RI D. Ha m b y, 011ef, Reactor Projects Section 4A, RI D.' Holody, Jr., EnfatVement Officer, RI M. Knapp, Director, Division of Radiation Safety and Safeguards, RI R. Nimitz, Senior Health Physicist, RI
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W. Raymond, Senior Resident Inspector, Millstone
R. Rosano, Office of Enforcement E. Wenzinger, Sr., 011ef, Reactor Projects Branch 4, RI
Indicates those personnel who attended the Enforcement Conference by telephone.
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Purpose
'Ibe Enforcement Conference was held at the request of-NRC Region I.to rilam== the circumstances surrounding the shipnent of an underwater shear cutter (UPC) from Millstone Station to the Duane Arnold Energy Center, Palo, Iowa, where upon receipt it was determined that radiation levels on the exterior of
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the package containing the USC avrwvhd the regulatory limits as set forth by the U. S. Department of Transportation. 'Ihe cuscussion at this meeting few'_taad -
on the identified apparent violation, the root cause of the event and licensee
- wu.=ctive actions to prevent recurrence.
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Licensee Presentation
1he licensee's presentation, which consisted of a series of view graphs and.
agrepriate discussion, are attached. 'Ihe licensee did concur that the item identified was a violation, but =L.h its low safety significan::e and the actions taken by the licensee in dewit inating.the USC prior to shipnent as cause for reduction of the severity level of the violation, and mitigation of any civil penalty amane' lated with the violation.
4.
Concluding Statements NRC Regicm I management stated its concern that this was the second Enforcement Ctnference within the past year with the licensee un w uing transportation and contamination control. NRC Pagion I management stated that the licensee would be informed of the need and the nature of apsvriate enforcement action relative to this violation at a later date.
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Docket Nos.'50-245 l
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' Radioactive Materials Shipment to Duane Arnold Energy Center
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Northeast Nuclear Energy Company February 20, 1990
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DescriDtion of Event ^
On ? Friday, January 19, 1990, Northeast Nuclear Energy Company- (NNECO) was-notified by Duane Arnold Energy Center personnel that a radioactive materials
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. shipment arrived at ' their facility with a contact reading in _ excess of the E
limits-allowed per 49CFR173.441 - and 10CFR71.47.
The shipment contained an
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' underwater shear cutter (USC) owned by WasteChem Corporation.which was used at
. Millstone Unit No. I to cut control rod blades.
It was shipped from the Millstone Station on Wednesday, January 17, 1990 and arrived at the Duane Arnold Energy Center on Friday, January 19, 1990.
The USC is a hydraulically controlled press and shear.
Its primary function is to flatten a control rod blade and then cut it-into desired lengths.
All USC cutting operations are conducted under water in the spent fuel pool.'
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The cutting machine arrived at the Millstone Station on November 8,1989 and-
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was operated in the Millstone Unit No. I spent fuel pool at various times during November and December 1989.
NNEC0 was aware of _ concerns associated with the -shipment of this type of equipment as delineated in' NRC Information Notice 88-101.
Accordingly, upon completion of the work, -significant efforts were put forth to decontaminate the USC and -eliminate any loose contamination (e.g.,
hot particles) in preparation for shipment.
The package was then placed on a flatbed truck and 1 shipped as LSA, exclusive use, on an open transport vehicle.
The size of this package (i.e., 8' x 8' x 12') precluded shipment of this package in a closed transport vehicle, which would have been the preferred means of transport per normal station practices.
At the time of departure from the Millstone Station, the vehicle was in full co.npliance with all NRC and D0T requirements
for the shipping'of radioactive matarials.
L Upon arrival at the Duane Arnold Energy Center, a survey was. performed on the shipment,.and a reading of 200-300 mR/hr-was iaund on the package surface in an area approximately 3" x 5" on the bottom.of the package.
The location of
- the hot spot was such that it was not readily-accessible to personnel nor accessible by the whole body.
The reading beneath the trailer, under the hot-spot, was 30-45 mR/hr--well within the transportation limits -for the trailer.
Cause of Event The USC was decontaminated, packaged, inspected, surveyed, and shipped from the Millstone Station with considerable effort taken to ensure that actions were performed in accordance with all requirements of the-NRC, D0T, and station procedures.
Sometime during transport, a hot particle / fragment in the shipment-apparently moved or dislodged, changing the external surface ' dose rates on the-package.
Movement of the unit within-the package was not possible since the unit was securely bolted in place.
The root cause of this high dose rate on the exterior surface of the package
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was the - inability, despite the substantial efforts on the part of NNECO personnel, 'to identify potential movement of a hot particle / fragment in the shipping package. Based -upon evaluations'done at the time of decontamination, it was: believed that all major hot spots on the cutting unit were eliminated or fixed.
This conclusion was apparently incorrect.
Contributing to this v
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event is the'overall design of the cutting unit which has considerable inter-
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nal areas for potential entrapment of cutting debris.
NNECO recognized this potential before shipping and took reasonable and proper actions to minimize the likelihood that a hot particle / fragment would remain on the unit when shipped.
Analysis of Event Surveys on the package prior to its departure from Millstone Station indicated that the maximum surface dose rate on the package was 90 mR/hr.
Readings taken at the Duane Arnold Energy Center indicate that the maximum contact dose rate was 200-300 mR/hr in a 3" by 5" area located approximately one foot from the highest reading (90 mR/hr) observed by Millstone Radioactive Materials Handling (RMH) Health Physics personnel.
Evaluation by the Health Physics Staff at the Duane-Arnold Energy Center indicated that the source of the elevated radiation level was due to a hot spot on a chute in the lower section of the USC.
This area did not have a dose rate of more than 50 mR/hr when.
Millstone Unit 1 Health Physics personnel surveyed the unit prior to packag-ing. A schematic representation of the package is attached.
o Decontamination NNEC0' personnel performed the following activities in support of the decontamination effort in preparation for shipment:
To reduce dose rates on the USC, decontAnination using a hydrolazer
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was initiated in the spent fuel pool.
After decontamination, a survey was performed to identify those areas where high radiation levels persisted.
This process was repeated for four cycles.
However, several hot spots were noted on the USC that could not be removed by hydrolazing.
The USC was removed from the fuel pool and moved to a tent on the
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refueling floor.
A survey was performed identifying areas for further decontamination.
The unit was wiped down, resulting in further reduction of radiation
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level s.
However, a 1.5 R/hr hot spot in a weld seam could not be reduced further by hydrolazing or wiping.
The 1.5 R/hr hot spot was assessed by Unit 1 Health Physics person-
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nel to be fixed in the weld seam.
A scanning survey of the lower section of the unit indicated that, notwithstanding the hot spot, the shipping limits on the package surface would not likely be exceeded.
The USC was then wrapped in plastic and placed into its shipping
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package.
The package contents were braced into place.
Members of the Quality Services Department (QSD) and the RMH organization then inspected the wrapping and bracing to ensure QC hold points had been
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adequately satisfied.
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- A ~ radiation. survey - was done on the ' shipping package and it was
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- deemed to be in a satisfactory condition for final preparation by the RMH personnel.
The ' package was then transported to RMH personnel for shipping
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preparations.
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This effort required nearly 140 manhours and expended 0.89 man rem.
(Includes all labor).
'o Packaae Preparation
RMH personnel prepared the package for shipment, including the following
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activities:
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_A detailed, second survey of the package was completed. -Due to the
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size of the package ' and the detailed level of the survey, this effort required approximately six manhours.
The result of this survey indicated that the maximum contact dose rate on the box was 190 - 200 mR/hr. This area was approximately-three inches square.
The Radioactive Materials Handling Supervisor assembled Health
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Physics technicians from the RMH group and Unit I to conduct a joint inspection of the package and its contents. Based upon this inspec-tion, it was concluded that the maximum contact dose rate on the package was directly attributable to the fixed 1.5 R/hr hot spot on the USC.
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Dunnage was added to the outside of the package over the central
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area where the highest contact dose rate was found. The dunnage was banded to the full width of the box over the entire central section, i
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The additional packing materials lowered the maximum contact dose 1-rate on the shipping package to 90 mR/hr, well below the Millstone e
Station administrative shipping limit of 160 mR/hr for a package on an open transport vehicle.
L All work was done in accordance with an Automated Work Order (AW0).
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All package preparation requirements were satisfied, and all QC hold points were properly completed and verified by QSD personnel and the RMH Supervisor prior to releasing the shipment.
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o Duane Arnold Enerav Center Assessment of Packaae o
Upon arrival at the Duane Arnold Energy Center, a survey was performed on the shipment, and a reading of 200-300 mR/hr was found on the package surface in an area approximately 3" x 5" on the bottom-of the package.
Evaluation by Health Physics Staff at Duane ' Arnold indicated-that the L
source of the elevated radiation level was due to a hot spot on a chute li-in the lower.section of USC.
The reading beneath the trailer, under the hot spot, was 30-45 mR/hr.
Despite the reasonable and proper efforts of highly qualified NNEC0 personnel
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to decontaminate, package, and ship the USC in compliance with all NRC and D0T
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regulations, it appears that upon arrival at the Duane Arnold Energy Center, the limit for maximum dose rate was exceeded.
Assessment of Safety Sianificance The shipment was transported by an exclusive use vehicle.
This precluded
' h.andling of the package by personnel not authorized to receive and/or handle radioa::tive materials during conditions normal to transportation.
Upon i
receipt at the Duane Arnold Energy Center, the package was surveyed by.quali-fled and knowledgeable personnel in accordance with the regulations.
According to Duane Arnold Health Physics personnel, the limit for the maximum surface dose rate (200 mR/hr) on the package was exceeded upon arrival at the Duane Arnold Energy Center.
The hot spot (approximately 3" x 5") was not readily accessible because:
(1) the hot spot was located on the bottom of a 26,000 pcund shipping container, (2) the hot spot was located greater than 3 feet from an accessible edge of the. package, and (3) the clearance between the flatbed surface and the package was only approximately 4 inches.
In addition, there was minimal opportunity for public or personnel access to the' hot spot as the shipping container could only be moved by a forklift or similar device.
The contact reading on the trailer beneath the hot spot was 30-45 mR/hr.
All other dose rates associated with the shipment were in conformance with applicable regulations.
No whole body dose rate in excess of 200 mR/hr could s
have been obtained due to the location of the spot.
Since the risk to the general public was no greater than the risk deemed
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acceptable by existing regulations given sat the hot spot was not readily
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accessible, this event is not safety significant.
Corrective Action Based upon our investigation of this event, NNEC0 has identified areas in its radioactive materials shipping program that could be enhanced.
First, additional preshipment supervisory reviews will be performed.for these types of shipments. The purpose of these reviews will be to:
o Add another level of evaluation regarding the potential for and consequences of radioactive particle movement during shipping.
Determine appropriate -contingency measures (e.g.,
additional precautionary dunnage), based upon the results of this evaluation and regardless of low perceived potential for hot particle / fragment movement during shipping, to increase level of assurance of complying with applicable regulations.
The review shall be done jointly by the Radioactive Materials Handling Supervisor, the Radiation Protection Supervisor of the Unit involved, and engineering personnel familiar with the eqiHpment.
Additional controls, I
specific to the shipment shall be included in ne inspection plan required by the AW0.
The resulting inspection plan will be reviewed and approved by the Health Physics Manager, Support.
Procedure changes to include the above
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actions are presently under Station Management review and will.be completed by
L February 28, 1990.
p Secondly, since norma 1 ' station practice would have been to utilize a closed transport vehicle for this type of package, future vendor contracts for
. spec ai l cutting services will include provisions for the vendor to either L
supply. a package-which can. be loaded into a closed transport vehicle or to L
provide. a - personnel barrier for use on an open transport vehicle.
These improvements in vendor packaging would not necessarily preclude NNEC0 from
' taking the 'above mentioned precautionary contingency measures.
Use of the closed; transport vehicle allows for packages of up to 1,000 mR/hr contact
. surface dose rate.
This extra safety margin recognizes the extreme difficulty associated with-the assessment of transportable radioactive particles in the
- shipping package. The-level of effort.to keep the package surface dose rates as low as reasonably achievable will not be diminished as a result of. the extra safety margin.
- NNEC0 recognizes that movement of hot particles / fragments within packages of this type has been an industrywide-problem.and will therefore be contacting the appropriate vendors to suggest improvements and possible ',eengineering of existing packaging methods, t
- Conclusion Reasonable and proper efforts were made by highly qualified NNEC0 per.sonnel to
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discover and remove hot ' particles from the USC prior to shipment from the Millstone Station-to the Duane Arnold Energy Center.
(In fact, the shipment -
- was in full compliance with applicable regulations when it left the Millstone
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Station.)
Notwithstanding these efforts,.a hot particle apparently moved or dislodged during transit, causing the maximum dose rate un the bottom surface of the package to exceed 200 mR/hr in a 3" x 5"' area.
NNECO believ'es that this event is not safety significant in that the risk.to
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the general public was 'no greater than the risk deemed acceptable by existing regulations given that the hot spot was not readily accessible.
1he ir.cident does-not represent a willful violation or indicate a breakdown in management
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controls.
On the contrary, we believe our actions were proper, s3'nificant and reasonable.
In addition, appropriate corrective actions are
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implemented.
Based upon all the above. factors, NNECO believes that it is appropriate for the NRC to exercise discretion when considering enforcement action.'regarding this.' event.
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ATTACHMENT
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HARRY F. HAYNES DIRECTOR, MILLSTONE UNIT SERVICES
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4 - TYPE B SHIPMENTS i
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RADI0kaMVEMATERIALSHANDLERSTRAINING I
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i-i PERSONNEL QUALIFICATIONS. RADIDACTIVE MATERIALS RANDLING Charles R. Palmer. Manaaer.- Health Physics Support t
' B.S., Nuclear Engineering, The Pennsylvania State University
. M.S.,- Nuclear Engineering, The Pennsylvania State University
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1971 --1975-United States Navy (
1975 - 1977 Mare Island Naval Shipyard,
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Radiological Engineering 1977 - 1981 Associate Engineer, Engineer, Sr. Engineer, Radiological Assessment Branch, NUSCO
,
- 1981 - 1983 Supervisor, Health Physics Program, NUSCO 1983 - 1985 Principal Specialist, HP, Caro?ina Power & Light i
Company, Shearon Harris Energy 4.nd Environmental Center.
1985 - 1988 Principal Engineer, Radiological Assessment Branch, NUSCO.
1988 - Present
- Manager, Health Physics Support, Millstone Nuclear
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Power Station.
Steven M. Turowski Radioactive Materials Handlina Supervisor
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B.S., Medical Physics, Oakland University M.S., Health: Physics, University of Florida (internship at Crystal River)
L-1982 - 1984'
Associate Scientist,- Radiological Assessment Branch I
c 1984L-1988 ALARA Coordinator, Millstone Unit 3 t
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- 1988 ' Present Radioactive Materials Handling Supervisor L1 Gary F. Seckinaer.~ Assistant Radioactive Materials Handlina Supervisor
. 1967
.1970 Wesleyan University
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1974 - 1978 Health Physics Technician, General Dynamics,
Electric Boat Division
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L-1978 -.1986-Health Physics Technician, Millstone Unit 1 1986 - Present Assistant Radioactive Materials Handling Supervisor j
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Francis M. Matovih. Lead Health Physics' Technician Attended Cleveland Junior College and Penn State University 1968 - 1974 United States Navy 1975 - 1977 Health Physics Technician, General Dynamics, Electric Boat Division 1978 - 1979 Health Physics Technician, NLMANCO, Inc.
1979 - 1983 Senior Radiation Protection Technician, Radiological Assessment Branch 1983.- 1988 Senior Health Physics Technician, Millstone Unit 1 1988 - Present Senior (lead) Health Physics Technician, Radioactive Materials Handling
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