IR 05000255/1998018
| ML18066A309 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/01/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18066A308 | List: |
| References | |
| 50-255-98-18, NUDOCS 9810060171 | |
| Download: ML18066A309 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION Ill Docket No:
License No:
Report No:
Licensee:
Facility:
.Location:
Dates:
Inspector:
Approved by:
9810060171 981001 PDR ADOCK 05000255 G
PDR 50-255 DPR-20 50-255/98018(DRS)
Consumers Energy Company Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530 August 24 - September 2, 1998 R. L. Glinski, Radiation Specialist Gary L. Shear; Chief, Plant Support Branch 2 Division of Reactor Safety
EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/98018 The purpose of this inspection was to review a transportation incident in which a Class 7 (radioactive) package, that was shipped as an exclusive use shipment on an open transport vehicle, exceeded the NRC and Department of Transportation (DOT) limits for radiation levels on the external surface of the package. In addition, this review covered the implemer:itation of transportation procedures, the preparation of shipping papers, and the performance of radiation surveys conducted in support of this shipment. The following conclu.sions were reached:
An apparent violation was identified concerning the failure to transport a package of radioactive material in accordance with 49 CFR 173.441, i.e.~ radiation levels on the external surface of the package exceeded the stated regulatory limits. However, due to indications that inherent problems with the cask may have been the cause for the violation, the actual root cause of the violation could not be determined at the time of the inspection. (Section R 1. 1)
The shipping papers for the radioactive material shipment were prepared in accordance with regulations, plant procedures and expectations. However, several aspects regarding both survey and documentation practices for the shipment did not meet either procedural requirements or management expectations, and the lack of normally available personnel resources contributed to these deficiencies. (Section R4.1).
Report Details IV. Plant Support R1 Status of Radiological Protection and Chemistry {RP&C) Controls R1.1 Radiological Controls for the Loading and Preparation of a Shipping Cask Inspection Scope (IP 86750)
The inspector reviewed the radiation work permit (RWP}, radiological surveys, and dosimetry data for the loading and temporary storage of a Type A shipping cask. The inspector also interviewed plant personnel regarding the controls implemented during this evolution, and the inspector interviewed plant and vendor personnel regarding the radiation levels detected by the engineering vendor at their site upon receipt of the packag Observations and Findings On August 12, 1998, plant personnel removed a highly irradiated reactor surveillance capsule from the spent fuel pool (SFP) and placed it into a Type A shipping cask. The capsule had been previously placed into a specially designed holding basket and had been allowed to decay for 114 days in the SFP. This particular task involved transferring the capsule/basket from the SFP to the shipping cask, as the cask was suspended over the SFP. The licensee had contracted to transport this surveillance capsule to an engineering vendor for metallurgical analyses, and an experienced vendor representative was onsite to aid in the proper loading of the cas A previous assessment by the vendor (based on the chemical composition of the capsule, the neutron irradiation from its accelerated position in the vessel, and a 60-day*
decay period) had estimated a maximum dose rate of approximately 106 millirem per hour (mrem/h) at the centerline of the loaded cask. The initial surveys of the loaded cask on the refuel floor detected a maximum dose rate of 110 mrem/h on contact. Based on dose rates that were consistent with the vendor's estimation and the assistance of the contractor, licensee staff concluded that the capsule/basket assembly had been correctly loaded into the cask. The end plates were bolted onto the loaded cask, which was then transferred to the shipping bay and secured onto the dedicated flatbed trailer. During this evolution, the licensee expended 45 mrem whole body dose and less than 20 mrem extremity dose, which were reasonable for the work accomplishe Radiation surveys of the cask and trailer bed, which were performed to determine the appropriate radiological postings for the area, were consistent with the initial surveys on the refuel floor. On August, 14, 1998, the radioactive materials shipping supervisor (RMSS) and a health physics technician (HPT) conducted a more extensive survey of the cask and truck/trailer in preparation for shipment. The dose rates at the truck cab and at 2 meters from the lateral surfaces of the vehicle were within the regulatory limits and were also consistent with the estimates provided by the engineering vendo *
However, the RMSS detected a single area on the bottom of the cask surface with a radiation level of 170 mrem/h, which was verified by the HPT.
On August 17, 1998, the RMSS reviewed the shipping papers with the carrier, reviewed the shipment surveys, and examined the material condition and placarding of the traile After reviewing the instructions for this exclusive use shipment with the carrier, the RMSS allowed the shipment to leave the site. This shipping cask (Serial No. TTC-5)
was an authorized Department of Transportation (DOT) Specification 7 A Type A cas On August 18, 1998, the carrier delivered the shipment to the vendor's sub-contractor facility, as this sub-contractor was to conduct the metallurgical analysis of the surveillance capsule. However, the shipping papers specified that the engineering vendor was to receive the shipment. In addition, the sub-contractor surveyed the cask and found a discrete area on the external surface of the package with a radiation level of 300 mrem/h, which was in excess of the regulatory limit of 200 mrem/h for an exclusive use shipment on an open transport vehicle. The sub-contractor contacted the NRC in accordance with 10 CFR 20.1906(d)(2), and then contacted the license The licensee immediately dispatched the RMSS and the site health physicist to the sub-contractor's site to examine the cask and conduct a confirmatory survey. Prior to reviewing the sub-contractor's data, the RMSS conducted a survey and identified an area of approximately 10 centimeters (cm) in diameter* having radiation levels of 280-380 mrem/h, which was consistent with the sub-contractor's measurements. This area was approximately 0. 75 meters from the 170 mrem/h area that was identified at the licensee's facility. The RMSS also found the 170 mrem/h area and indicated that it appeared to have moved several cm axially along the bottom of the cas O CFR 71.S(a) requires that a licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers 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 in 49 CFR Parts 170 through 189. 49 CFR 173.475(i) requires, in part, that before each shipment of any Class 7 (radioactive) materials package, the offeror must insure by examination or appropriate tests that the external radiation levels are within the allowable limits in 49 CFR Parts 171-178. 49 CFR 173.441(a) requires, in part, with exceptions not applicable here, that each package of radioactive materials offered for transportation be designed and prepared for shipment, so that under conditions normally incident to transportation the radiation level does not exceed 2 millisieverts per hour (mSv/h) (200 mrem/h) at any point on the external surface of the packag The existence of external surface radiation levels in excess of the applicable regulations is an apparent violation of NRC and DOT requirements (EEi 50-255/98018-01).
However, interviews with the licensee, the engineering vendor, and with another nuclear facility, indicated that there may be an inherent problem with the design and/or manufacture of the cask, which could have been the root cause or a contributing cause of the violation. During the removal of the basket/capsule assembly from the cask,
various personnel obser\\ted that very slight mc;wements of the basket/capsule resulted in significant fluctuations of the radiation levels on the surface* of the cask, from 280 mrem/h to 190 mrem/h. In addition, another nuclear facility which had used this cask for the same purpose in 1997 stated that their surveys detected two discrete areas on the cask where there appeared to be streaming of radiation through possible voids in the cask shielding. Finally, the engineering vendor stated that, based on the design of the basket, basket holder, and cask, there was a potential for the basket/capsule assembly to move up to 5 cm in the cask. Since the cask was mounted on the truck bed at approximately a 10 degree angle, the inspector concluded that the basket could have moved during transport, which would be due to cask design, and that the movement could have.contributed to the increased contact dose rate Based on the information stated above, the actual root cause of the violation {either inadequate survey/preparation of the shipment or inadequate design/manufacture of the cask) could not be determined at the time of the inspection. However, the licensee and it's vendor were evaluating the cask and this incident to determine the root caus Conclusions An apparent violation was identified concerning the failure to transport a package of radioactive material in accordance with 49 CFR 173.441, as the radiation levels on the external surface of the package exceeded the stated regulatory limits. However, due to indications that inherent problems with the cask may have been the cause for the violation, the actual root cause of the violation could not be determined at the time of the inspectio R4 Staff Knowledge and Performance in RP&C R Poor Performance in Implementing the Shipping Procedure for Shipment 98-067 Inspection Scope (IP 86750)
The inspector reviewed the applicable procedure {Procedure No. HP 6.20, "Radioactive Material Shipments") and the shipping papers associated with radioactive material
{RAM) Shipment No.98-067 and interviewed supervisory personne Observations and Findings The inspector noted that the shipping documents required for this exclusive use shipment were generally well prepared. The vendor performed the calculation for the curie content of the capsule; the results were reviewed by licensee personnel; and the inspector noted that the methodology was in accordance with industry practice. The shipping papers contained the information required by 49CFR 172 (waste classification, reportable quantity, physical and chemical form, radiation levels, emergency response information, volume, weight, total activity, and the 95% rule for listing radionuclides) and were signed by authorized shipping personne '
However, during the personnel interviews and the comparison of the shipping documentation with the applicable shipping procedure, the inspector noted that several aspects of this shipment did not meet procedural requirements or management expectation *
In Section 5.1, the procedure stated that radiation levels in excess of 75% of the applicable limits should be verified and documented on the appropriate container survey form. After the RMSS detected the 170 mrem/h contact radiation level (85% of the applicable limit), he instructed an HPT to verify the radiation level at that single location. The environmental supervisor indicated that the RMSS should have instructed the HPT to verify the entire cask survey. In addition, the verification survey was not documented on the appropriate for *
Per Section 5.2, the environmental supervisor authorized the extension of the maximum radiation levels on packages above the 75% administrative level, but this supervisory authorization was verbal and not written. Although the procedure required that the authorization be retained in the appropriate shipment packet, this authorization was not retained with the shipment packe *
Per Section 6.13, the consignor (licensee) issued specific instructions in writing for the maintenance of exclusive use shipment controls and included them with the shipping paper information provided to the carrier. However, the licensee did not keep a copy of the written instructions that were signed by the carrier for the licensee's records or for inspection review. This was a concern as the carrier delivered this shipment to the sub-contractor and not to the engineering vendor, which was the consignee (receiver) on the shipping papers. Although no violation of regulatory requirements was identified, the delivery of this exclusive use shipment to an entity other than the listed consignee necessitated a revision of the shipping papers and the procurement of a copy of the actual receiver's license, to ensure the sub-contractor's authorization to possess this RA *
Section 9.3.1 required a Bill of Lading for all exclusive use shipments, and 9.. required that the Bill of L~ding include the transport index for each package in Radioactive Yellow-II or Yellow-Ill shipments. However, the transport index was not included on the Bill of Lading for this Radioactive Yellow-Ill shipmen *
Attachments 4 and 7 of the procedure required the acknowledgment of any survey data in excess of 150 mrem/h and/or 75% of the limits, respectively, on these forms. Although the RMSS had detected and verified the existence of 170 mrem/h radiation levels on the surface of the package, he did not acknowledge this on either of these attachments. The RMSS indicated that he mistakenly thought that 175 mrem/h was the correct radiation level which corresponded to the 75% limit specified on these form Although some of these instances did not meet procedural requirements, the RAM shipping procedures were not required by the plant Technical Specifications (TS) and, therefore did not constitute examples of TS procedural violations. However, the
- inspector expressed concern that several instances of failure to comply with written instructions or management expectations occurred with this shipmen During the interview and document reviews, the inspector noted that the RMSS had performed the radiation surveys and reviewed the data and shipping papers. Normally, HPTs would perform the surveys and the RMSS would provide an independent, supervisory review of the data. However, due to the lack of HPT availability during this time, the RMSS conducted the surveys and reviews, thereby precluding an independent review which may have identified some of these deficiencies to meet plant expectation C&RS supervision planned corrective actions to address the issues identified from this transportation incident. These plans included the documentation of the reviews and use of vendor procedures, required documentation for any verification surveys, written authorization by a minimum of two supervisors to conduct a shipment with radiation levels in excess of 80% of the regulatory limits, and revision of the procedures and forms to reflect these changes. In addition, the C&RS staff obtained the services of an experienced transportation vendor to review shipping procedures and practice Conclusions Overall, the shipping papers for the RAM shipment 98-067 were prepared in accordance with plant procedures and expectations. However, several aspects regarding both survey and documentation practices did not meet either procedural requirements or management expectations, and the lack of normally available personnel resources contributed to these deficiencie X1 Exit Meeting The inspector presented these inspection findings to members of the licensee's management during an interim exit meeting on August 26, 1998, and at a final teleconference exit meeting on September 3, 1998. Plant personnel did not indicate that any information in this report was considered proprietar PARTIAL LIST OF PERSONS CONTACTED Licensee M: Banks, C&RS, Manager J. Beer, Technical Support Supervisor R. Burdette, NPAD Examiner B. Dotson, Licensing Analyst G. Goralski, Configuration Control Manager N. Haskell, Licensing Director R. Henry, Radiation Material Shipping Supervisor D. Malone, Licensing Manager D. Malone, Engineering Manager M. Menucci, C&RS Assessor T. Neal, Environmental Supervisor T. Palmisano, Site Vice President and General Manager C. Plachta, Radiation Protection Manager, Radiological Services Supervisor D. Rogers, General Manager Plant Operations G. Szczotka, NPAD Manager D. Smedley, Licensing Supervisor D. Watkins, Duty HP Supervisor J. Lennartz, Senior Resident Inspector, Palisades IP 86750 Opened INSPECTION PROCEDURES USED
"Solid Radioactive Waste Management and Transportation of Radioactive Materials" LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED 50-255/98018-01 EEi Failure to prepare a shipment of radioactive material such that the radiation levels will not exceed 200 mrern/h on the external surface of the package. (Section R1.1)
C&RS cm CR DOT EEi HPT mrem mrem/h mSv/h RAM RMSS RWP SFP TS ACRONYMS USED Chemical and Radiological Services centimeter Condition Report Department of Transportation Escalated Enforcement Item Health Physics Technician mi Iii rem millirem per hour millisieverts per hour Radioactive Material Radioactive Material Shipping Supervisor
- Radiation Work Permit Spent Fuel Pool Technical Specifications
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- PARTIAL LIS.TING OF DOCUMENTS REVIEWED Technical Specifications Section 6.4 - Procedure Shipping Package for Radioactive Material Shipment 98-06 Incident Response Team Report - Reactor Surveillance Capsule Shipmen Condition Report C-PAL-98-153 Procedure No. HP 6.20, Revision 14, "Radioactive Material Shipments".
RWP 980230, Revision 0, "Load Cask with Surveillance Capsule".
Work Instruction Wl-RSD-R-013, Revision 1, "Surface Contaminated Object Shipments".
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