IR 05000255/1992008
| ML18058A316 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/20/1992 |
| From: | Markley A, David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A314 | List: |
| References | |
| 50-255-92-08, 50-255-92-8, NUDOCS 9203310136 | |
| Download: ML18058A316 (10) | |
Text
U.S. NUCLEAR REGULATORY COMM I SS ION
REGION III
Report No. 50-255/92008(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company Palisades Nuclear Generating Plant 27780 Blue Star Memoria 1 *Highway Covert, MI 49043 Facility Name:
Palisades Nuclear Generating Plant
. Inspection*At:
Palisade~. Site, Covert, Michigan Inspection Conducted:
February 6 through 20, 1992 Inspector: A.~~ I~
Senior Radiation Specialist D.~~~/.._
Radiation Specialist Accompanying Inspector: S. K. Orth w~~
Approved By:
William Snell, Chief Radiol6gica1* Controls Section Inspection Summary.
License No. DPR-20 Dat Date **
Date
Inspection on February 6 through 20, 1992 (Report No. 50-255/92008(DRSS))
Areas Inspected: Special, announced inspection of the radiation protection,*
radwaste and transportation programs, including: management controls and training for contract radiation protection technicians, solid waste and transportation.(IP 837~0, 84750, 86750). Also reviewed was an unresolved item associated with radioactive waste processing and storage facilities*
(IP 84750, 86750).
Results:- One violation associated with a spent fuel rack shipment was identified. The violation was for a failure to establish a 24-hour emergency response telephorie number which was monitored at all times and a failure to document this number on ~he shipping paper A follow up evaluation of the radioactive waste processing and storage faciliti~s resulted in the identification of four additional examples of failures to perform a safety evaluation in accordance with 10 CFR 50.59 for which a previous Notice of Vio~ation had been issue PDR ADOCK 0500025 PDR -
DETAILS Persons Contacted
.@ P. Brute, Safety Eva luatiOn Coordinator
N. Campbell, Senior Health Physicist
- @ P. Donnelly, Director, Safety and Licensing
- J. Fontaine, Senior Health Physicist
M. Grogan, Radwaste Co6rdinator
- @ K. Haas, Radiological Services Manager
- J. Hadl, Senior PA Consultant
@ C. Hillman, Licensing Coordinator
R. Kasper, Maintenance Manager
- L. Kenaga, Health Physics Superintendent
- @ J. Kuemin, Licensing Administrator
- P. Loomis, Performance Specialist
- D. Malone, ALARA Supervisor
- R. McCaleb, NPAD Specialist M. Mennucci, Senior Health Physicist *
- @ T. Neal, Radioactive Materials Administrator
- K. Osborne, System Engineering Manager
- T. Palmisano, Administration and Planning Manager
R~ Philips, NECO Engineering P~ograms
- T. Popp, General Health Physicist
- R. Rice, Operations Manager, Acting Plant Manager
- D. Rogers,* Traintng Administrator
- P. Rigozzi, ES Training Administrator
G. Slade, Plarit Manager
- K. Toner, Manager, Electrical, I&C, and Computer Engineering J. Heller, Senior Resident Inspector
- @ R. Roton, Resident Inspector The inspectors also interviewed other.Licensee and contractor.personnel during the course of the inspectio * Denotes those present at the interim exit meeting on February 6, 1992.
- Denotes those present at the interim exit meeting on February 14 9 199 @ Denotes those present at the telephone exit meeting on February 20, 199.
General This inspection was conducted to review a transportation incident involvin~ the shipment qf a spent fuel storage rack, review the licensee's evaluation of an NRC identified unresolved item regarding th~ implementation of general design ~riteria for radioactive waste processing and storage facilities, and radiation protection and ALARA preparations for a scheduled refueling and maintenance outag The inspection included tours of radiation controlled areas, containment, auxiliary bui.lding, radwaste facilities, observations of licensee
.*activities, review of representative records and discussfons with *
licensee personne.
Sp~nt Fuel Storage Rack Transportation Incident
,.
- Event Chronology During the 1981 time frame, this spent fuel storage rack wa~ placed in. the Spent Fuel Poo As reported by the licensee, this rack was not used to store spent fue In 1982, the rack was removed from the pool, hosed down with clean water, wrapped in plastic, crated and stored in an upright position at the East Radwaste Building (ERW).
- Prior to February 5, 1992, the *licensee had made arrangements with the Quadrex Recycle Center in Oak Ridge, Tennessee to ship the rack to their facility for decontamination, volume reduction and eventual salvage. Quadrex agreed to provide a specially designed sea/lind container for the shipmen *
On the morning of February 5, 1992, radwaste personnel readied the rack for loading into the sea/land container. The rack was rotated from a vertical to a horizontal position. During the maneuv~r, however, the ~eight of the rack (26,000 pounds) put a strain on the wooden crate which caused the bottom of the crate to detach. At this time, workers noticed that a small ~~o~nt of water was leaking from the open end of the crate. The water appeared to come from the front or top of the rack. Samples of the water were frisked and..
placed in a PCM-18 portal monitor but no acttvity above background was detecte The licensee indicated that water continued to drip from the rack for approximately.10 - 15 minute The rack was held in position for an additional hour aft~r the dripping had stoppe The carrier's driver arrived during this period and noticed that water had leaked from the rack and that the rack was being allowed to drai The inside of the sea/land container was equipped with a heavy duty tarp which compl~tely covered the back, sides and bottom of the container. The front section of the tarp was a flap type device similar to a tent openin The flap was secured to the top of the container but had openings at both front corners. The licensee placed approximately 200 pounds of Spedi-Dry absorbent over the bottom of the sea/land ~ontainer and set the crated rack into the containe The bottom of the crate was not reattached.and was left in the licensee's ER The lid was placed on the sea/land container, the flaps secured ahd shipping papers completed and distribute The loaded truck left the Palisades Plant at approximately 12:00 PM Eastern Standard Tim Approximately an hour later the truck driver pulled into a Sawyer, Michigan truck ~top for lunc Upon returning from Junch, the driver noticed that approximately two to three gallons of water had leaked from the sea/land container onto the flatbed, the tires and onto the truck stop parking lot. The driver immediately called his dispatcher and requested the truck stop management notify the loca authorities that a spill had occurre The driver indicated that
.*
his dispatcher accepted responsibility for notifying the license The dispatcher was unable to make contact _with the licensee's radioactive materials coordinator. The driver's "Instructions to Carrier" did not specify a telephone number to call in the event o an emergency or the name of an individual to*contact in the event of an emergenc The dispatcher also did no*t have the driver's instructions regarding ~roper actions to take in the event of *n emergenc The dispatcher was able to contact the receiver, Quadrex, regarding the spill.* Truck stop management called the local police who in turn contacted the State Of Michigan and the D_onald C. Cook Nuclear Power Plant. - The local police apparently understood that the shipment had originated from the Donald C. Cook Plant. Licensee personnel at Palisades learned of.the spill at 2:35 PM when a Quadrex employee called the plant to confirm that a spill had occurred.*
. By approximately 2:30 PM, the Berrien County Emergency Response.Team*
had arrived on the scene and had roped off the are~ surrounding the truck. Also present were several members of the local sheriff's office, a Radiation Safety Team sent from the Donald C. Cook plant and several reporters f~om the local pres The Palisades Radwaste team arrived at 3:40 PM and immediately beg-an to clean up the spill and collect samples for analysis. These samples were analyzed at both the Donald C. Cook laboratory and the Palisades laborator The truck, tires and collected liquids were all surveyed and found free of.activity. Preliminary results were immediately reported to the NRC by Palisades personne At approximately. 5:00 PM, the results of "no detectable" activity *
above background were received based on the laboratory analysis conducted at the Donald C. Cook plant and reported to all the parties involve At this point, the Berrien County Emergency Response Coordinator released the truck to return to Palisade The Radwaste team prepared the load for the return trip to Palisade *The sea/land container door seams were taped. This area was covered with plastic sheeting which was fastened to the shipping containe _Absorbent towels were placed inside the plastic sheeting to absorb any residual leakag At 6: 30 PM, the truck arrived at Pa 1 i sades and was secured inside the fenced area of the ER rhe next morning, February 6, 1992~ radwaste personnel noticed that small amounts of ice had formed on the trailer near the front door of the sea/land container.and-the absorbent towels placed around the door were very we At 11:30 AM, two NRC inspectors arrived on site to investigate the incident, collect samples for analysis and take surveys of the truck, bed and* tires. At approximately 12:00 PM, the lid of the sea/land container was remove The bottom of the contaitier had several areas of standing water and pockets of wet Spedi-Dr,
Approximately two and a half liters of water were collected *.
Subsequent analysis of all water samples, Spedi-Dry samples and smears displayed a similar pattern. Water samples showed Co-60 activity of *up to 2.56E-6 uCi/ml and Cs-137. activity of up to 4.
'.
- ----
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9.0BE-6 uC~/ml inside the sea/land container. These l~vels are low enough to qualify for release to the environment per NRC regulations and low enough that the water is not considered radioactive material per DOT regulations. Smear survey results indicated that no
- radioactive contamination was found on the exterior of the shipping *
containe One smear, taken on the lower support piece of the rac~
indicated approximately 12,800 dpm/100 square centimeters. Analyses of the Spedi-Dry in the bottom of the shipping container indicated activities approximately 10 to 20 times higher than the activity of the water. There was little if any activity detected in the
- spedi-Dry near the release points. The licensee's evaluation indicated that the Spedi-Dry filtered the water and concentrated the isotopes. The licensee's an~lyses of the leaking water outside of the shipping container indicated that no radioactive material leaked out of the packag On February 8-9, 1992, licensee personne 1 inspected the rack to determine the source of the wate The rack was composed of a matrix of hollow spaces surrounded by approximately 50 individual cells that contain neutron absorbing materia Each cell had a vent hole drilled at the top. According to the licensee, these holes were drilled to vent gases while th~ rack was in the spent fuel poo It appears that water entered the cells and little if any evaporation occurred following removal from the pool. Since the rack was stored in an upright position, the contained water appears to have remained undetecte However, after the rack was turned horizontal for shipping, it appeared that air entered the cell and allowed some of the water to escap Further examination showed that almost all of the vent holes had "rust smears" and several were blocked with debri If the rack was subjected to mechanical shock and vibration, such as normally incident to transportation, it appears that this would significantly facilitate the release of wate The licensee confirmed this by placing the rack on its side with a slight downward angle, applying a mechanical shock and observing water leaking from several of the vent hole They also heard sucking sounds from one of the cells followed by a relatively large discharge of wate The licensee conc)uded that the rack cells must have partially filled with water while submerged in the spent fuel pool in 198 When removed and stored in an upright position the rack was never allowed to drain. Licensee personnel estimate that the rack could have contained as much as80-100 gallons of wate Discussion of Leakage Licensee personnel acknowledged that the shipment should not have been made when water was observed leaking from the rac The licensee indicated that they have had several spent fuel rack shipments over the last ten years with no occurrences of leakag Since the water that leaked out of the container was not radioactive, there was no radiological significance to this even In additicin, based on discussions with NRC Headquarters and DOT, it was determined that there was no violation related to the water leaking from the shipment since the water that leaked was not radioactiv *
- c. * Emergency Instructions In the licensee's "Instructions to Carrier" under "Emergency Instructions", the driver is instructed to notify his dispatcher, local and/or State police and the shipper if-an emergency or accident occurs enroute~ If coriditions warrarit, s~ch as obvious *
leakage or apparent breach of a shipping' contafoer, the driver i also required to advise the shipper to notify the DOE Radiological Assistance Office. The document goes on to describe-the kind of information to provide to all parties contacted and provide generiC on-site emergency procedure The shipping papers did not identify an emergency number for contacting the shipper (licensee) or an emergency point of contac The document did not instruct the driver to immediately identify the nature of the accident (radiological, chemical, etc) or how to ha~dle a non-response from the switchboar The driver called his dispatche The dispatcher accepted responsibility, according to the driver, for contacting the shippe When the dispatcher called
- the licensee, he was advised that the radioactive materials shipping coordinator was unavailable. The dispatcher then notified the receiver (Quadrex) of the incident and reported-that he had been unable to notify the shipper. At approximately.2:35 PM (EST) or about one and a half hours after*the drive~ spotted the spill, Palisades was informed by the receiver. that the spill*had occurre The licensee has a procedure, HP 6.20, Radioactive Material Shipment
- Nonwaste, which describes the actirins required of the carrier during an emergency, required notifications, and the response required of Palisades personnel. *unfortunately, these instructions to the carrier were not included in the shipping document In house" procedures detailing steps.to be followed in the event of a shipping incident were never written. Responsible individuals and numbers where they could be reached were not assigned for radioactive material shipment Procedures should have been written and utilized to respond to a transportation incident especially in light of the requirements set forth in.49 CFR Subpart The licensee stated that they train all of their switchboard operators to respond to transportation incidents and have provided the operators with a notification form to be used in the event of an incident. The form lists sev.en pieces of information the o.perator must obtain before notifying plant management about the inciden The operators are then instructed to call one of the six i~dividuals listed on the form and convey the information collected. The inspectors also noted that a form that listed contact personnel was out of date ~nd included an individual who had transferred approximately two years earlier. The operator on duty the afternoon of February 5, 1992 remembers receiving the call from the shipping compan The individual asked to talk to the individua.l named as shippe When told that this individual was unavailable, the caller hung u The operator never knew that an accident had occ.urred until Quadrex called and.asked for information on the,"spill". The
- operato~ assumed that "spill" meant a chemical spill and transferred the called to the Chemistry Department who. in turn notified the
Radiological Services Department management..
.
6 *
The licensee failed to establish a 24.-hour emergency response telephone number which was monitored at all times or was accessible to an individual who had comprehensive*emergency response and incident mitigation informatio The licensee also failed to
.document the emergency response/contact telephone number on the: *
shipping papers. This is a.violation. of 10 CFR 71.5 and 49 CFR. *
172.604(a).
(Violation 255/92008-02}
d~
Corrective Acti~ns The licensee initiated-corrective actions to address the causes of the spent fuel transportation inci~ent and emergency instruction problems prior to completion of the inspection. The implementation of these cortective actions will be evaluated during a f~ture inspectio *
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The corrective actions for emergency instruction problems include:
(1) revising procedures to ensure adequate instructions for emergencies are provided to carriers of radioactive material shipments, (2) providing required emergency instruction information on shipping papers, (3) assigning a trained indiVidual as the
emergency contact, (4) requiring the emergency contact to wear a.
pager to ensure contact capability during transport of radioactive materials, (5) revising switchboard operator instructions, and (6).
training designated emergency contact personnel regarding duties and requirement * *
The corrective actions to address the causes of the spent fuel.rack transportation incident included:
(1) revising procedures to ensure that the radioactive material containers and materials are inspe~t~d for free standing liquids prior to transfer to storage or shipping, (2) providing additional instructions for performing container surveys, (3) requiring signed verification that a container does not contain free liquids, and (4) training responsible personnel to implement inspection requirement Two violations were identifie Radioactive Waste Processing and Storage Facilities (IP 84750, 86750)
Inspection Re~ort No. 50-255/91022(DRSS) dated November 29, 1991, identified and discussed a Notice of Violation for a failure to perform an adequate 10 CFR 50.59 evaluation regarding the reactivation of the South Radwaste Building (SRW) for radioactive material storage, and an Unresolved Item associated with apparent failures to. impJement general design criteria and Final Safety Analysis Report (FSAR)*commitmentsfor both the SRW and the East Radwaste Building (ERW).
The inspectors reviewed the licensee response to the Notice of Violation and their evaluation of the Unresolved Ite In addition, the inspectors performed a detailed evaluation of the licensee's design basis documents, original and updated FSARs, pertinent regulations that were effective during the requisite time frames, Atomic Energy Commission (AEC) Safety Evaluation Reports, Regulatory Guides,- Standard Review Plans, Integrated Plant Safety Assessment Report, I&E Circulars, Generic Letters, previous inspection
reports, and applications for a Full Tenn Operating License and for approval for disposal of radioactive materials fn situ near the SRW. ~These documents were reviewed to determine the li~ensee's obligations to the General Design Criteria (GDC) of 10 CFR 50, Appendix A and the regulatory basis for evaluating the licensee's radioactive waste processing and storage facilitie *
_This review indicated that the licensee had convnitted in their original FSAR and subsequent request fo~ a Full Term Operating License, to the
"proposed GDC" issued by the A~C-in 196 Further review determined
.that the licensee had adequately addressed all applicable GDC for their
~adioactive waste and processing facilities while these activities were located in the auxiliary building and the radwaste addition to the auxiliary building. -This ir1cluded the seismic criteria that the licensee conmdtted to implement for facilities that contained permanent processing equipmen These facilities and functions were described in the original FSAR and subsequent revision As such, the process of performing -safety evaluations as defined in 10 CFR 50.59 was applicable to the radioactive waste processing and storage facilitie This review also indicated that evaluation of applicable design criteria implementation for the radioactive waste processing and storage facilities at Palisades had been performed for initial licensing. The documentary evi_dence reviewed indicated that efforts since-initial
.licensi~g had been focused on reactor safet As a ~~sult of NRC reviews, a review of the licensee's evaluation,_
.interviews and discussions with the licensee, it was determined that the licensee failed to p~rform safety evaluations in accordan~e with 10_ CFR Part 50.59 for the followi~g activities~ The relocation of solid radioactive waste processing from the auxiliary building to the SRW building in 197 For temporary storage of radioa,ctive waste in the ERW buildin Temporary storage of radioactive waste commenced in this facility in 1980 and continues to the presen Fo~ modification and _expansio~ of the ERW. building in 198 For the relocation of solid radioactive waste processing from the SRW building to the ERW building in 1988. _
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These are violations of 10 CFR 50.59. - However, inasmuch as these violations are additional examples of failures in the licensee's program for which a previous 10 CFR 50.59 violation has been cited (Inspection Report 50-255/91022 (DRSS)), no Notice of Violation-will be issued at this tim The licensee has initiated corrective actions as noted in their January 10, 1992 response to the previous Notice of Violatio Thes~ corrective actions will help determine the scope of radioactiv~ waste processing and storage as well as radioactive material storage problems at Palisades. The licensee's evaluations of these facility changes must consider compliance with applicable regulatory requirements, such as 40 CFR 190, 10 CFR 20,
10 CFR 50; Appendices A and I, and 10 CFR 10 The licensee's evaluation addressing design criteria and guidance in response to the
- Notice of Violation were inadequate to address the four additional facility changes noted abov No violations or deviatioris were identifie.
Management Controls and Training for Contract RP Technicians (IP 83750)
The inspectors reviewed the license~*s management controls and training program for contract radiation protection technicians (CRPTs), including:
. selection of staff, training program requirements, testing of knowledge and skills, and verification of technician experienc The licensee has significantly upgraded its CRPT program sine~ the ~ompletion of the Steam Generator Replacement Outage (SGRP).
Procedures have been revised to
- specifically identify responsibilities for this program and to improve consistency of performanc The inspectors reviewed the resumes of technicians who were accepted for service by the licensee, the knowledge level examinations, and the efforts made by the licensee to verify CRPT qualifications. Overall,' excellent performance was noted, particularly in the efforts made to verify the qualifications of CRPT The knowledge level (screening) test was also very goo The test was comprehensive and had a suitable.range of difficulty in the types of questions utilize Although the licensee provided the CRPTs with an equation sheet, the CRPTs did have to know how to apply and utilize this information. Three individuals failed the screening examinatio Two of these individuals'
employment was terminate The remaining technician was evaluated and determtned to be acceptable *in accordance with the licensee's procedure No violations or deviations were identifie.
Plant Tours (IP 83750, 84750)
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The inspectors performed several tours of the containment, auxiliary building, radwaste facilities, and radiologically *controlled areas (RCA).
Housekeeping was generally very goo Personne.l access and exit from the RCA.was in accordance with procedure Good practices that were noted included:
(1) utilization of a continuous play video in the dressout room that provided instructions on the proper technique for wearin~ protective clothing, and. (2) utilization of a quiz during the logging in with the electronic dosimetry syste These questions covered specific radiological information identified on the radiation work permit (RWP).
Failure to answer the question correctly resulted in termination of access to that RWP until the individual reread*
his RWP and answered the question correctly. One minor contaminated area posting problem was identified in the containment near the B reactor coolant pum Licensee personn~l implemented corrective actions for this upon notificatio No violations or deviation were identifie *. Exit interview (IP 86750)
The inspectors met with licensee representatives (denoted in Section 1)
following the inspection on February 20, 1992, to discuss the scope and findings of the inspectio During the exit interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. Licensee representatives did not identify any such documents or processes as proprietary. The following items were specifically discussed with the license The violation associated with the incident involving transportat-ion of a spent fuel storage rack. (Section 3) The additional examples of a violation ~sso~iated with the failure to perform safety evaluations for the SRW and ERW building (Section 4)
10