ML061860740
| ML061860740 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/05/2006 |
| From: | Wert L Division of Nuclear Materials Safety IV |
| To: | Rosenblum R Southern California Edison Co |
| References | |
| EA-06-149, NMED 060138 IR-06-011 | |
| Download: ML061860740 (22) | |
See also: IR 05000206/2006011
Text
July 5, 2006
NMED 060138
Richard M. Rosenblum
Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: NRC INSPECTION REPORT 050-00206/06-011
Dear Mr. Rosenblum:
This refers to the inspection conducted on May 8-11, 2006, at Southern California Edison
Companys (SCE) San Onofre Nuclear Generating Station (SONGS), Unit 1 facility. This
inspection was an examination of decommissioning activities conducted under your license as
they relate to safety and compliance with the Commissions rules and regulations and with the
conditions of your license. The inspection included an examination of selected procedures and
representative records, observations of activities, and interviews with personnel. Additional
inspection and review was conducted from the NRC Region IV office and a final exit briefing
was presented telephonically to members of your staff on June 26, 2006. The enclosed report
presents the results of that inspection.
This inspection included a followup on an SCE transportation event reported on
February 23, 2006 involving a small quantity of low specific activity (LSA) radioactive material
which leaked from its transport container while in transit to a waste disposal site Utah. Proper
packaging of radioactive material for transportation on public highways is important to the
protection of public health and safety and the environment. Based on the results of this
inspection, three apparent violations were identified. The apparent violations involved SCEs
failure to: 1) ensure by examination or appropriate tests that the top discharge valve of the
package containing licensed material was properly closed and sealed, 2) load both intermodal
portable tanks to the required filling density, and 3) maintain, fill, and close the package used
for shipment of radioactive material, so that under conditions normally incident to transportation
that there will be no identifiable release of hazardous materials to the environment. The NRC
recognizes your staffs prompt corrective actions to remediate the spilled radioactive material.
These actions, combined with the low specific activity of the material shipped, ensured that
there was no significant risk to members of the public in unrestricted areas. However, it is our
understanding that a more thorough assessment of the packaging before shipment may have
prevented the leakage.
Southern California Edison Co. -2-
These violations are being considered for escalated enforcement action in accordance with the
NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site
at www.nrc.gov; select What We Do, Enforcement, then Enforcement Policy. The
circumstances surrounding the apparent violations, the significance of the issues, and the need
for lasting and effective corrective actions were discussed with your staff during the final exit
briefing. As a result, it may not be necessary to conduct a predecisional enforcement
conference in order to enable the NRC to make an enforcement decision. Since the NRC has
not made a final determination in this matter, no Notice of Violation is being issued for these
inspection findings at this time. In addition, please be advised that the number and
characterization of apparent violations described in the enclosed inspection report may change
as a result of further NRC review.
In addition, since SONGS-1 has not been the subject of escalated enforcement actions within
the last two years, and based on our understanding of your corrective actions to date, a civil
penalty may not be warranted in accordance with Section VI.C.2 of the Enforcement Policy.
The final decision will be based on your written confirmation to us that corrective actions are
implemented and are being taken.
Before the NRC makes its enforcement decision, we are providing you an opportunity to either
(1) respond to the apparent violations addressed in this inspection report within 30 days of the
date of this letter or (2) request a predecisional enforcement conference. If a conference is
held, it will be open for public observation, and the NRC will issue a press release to announce
the conference. Please contact Dr. D. Blair Spitzberg at (817) 860-8191 within 7 days of the
date of this letter to notify the NRC of your intended response.
If you choose to provide a written response, it should be clearly marked as a Response to
Apparent Violations in Inspection Report 050-00206/06-011; EA-06-149 and should include:
(1) the reasons for the apparent violations, or, if contested, the basis for disputing the apparent
violations, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate response is not received within the time specified or an extension of time has not
been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a
predecisional enforcement conference.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response (if any) will be made available electronically for public inspection
in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible,
your response should not include any personal privacy, proprietary, or safeguards information
so that it can be made available to the Public without redaction.
Southern California Edison Co. -3-
Should you have any questions concerning this inspection, please contact Dr. D. Blair Spitzberg
at (817) 860-8191 or Mr. Robert J. Evans, Senior Health Physicist, at (817) 860-8234.
Sincerely,
/RA/
Leonard D. Wert, Director
Division of Nuclear Materials Safety
Docket No.: 050-00206
License No.: DPR-13
Enclosure:
NRC Inspection Report Number 050-00206/06-011
Southern California Edison Co. -4-
cc w/enclosures:
Chairman, Board of Supervisors James D. Boyd, Commissioner
County of San Diego California Energy Commission
1600 Pacific Highway, Room 335 1516 Ninth Street (MS 34)
San Diego, CA 92101 Sacramento, CA 95814
Gary L. Nolff Douglas K. Porter, Esq.
Power Projects/Contracts Manager Southern California Edison Company
Riverside Public Utilities 2244 Walnut Grove Avenue
2911 Adams Street Rosemead, CA 91770
Riverside, CA 92504
James T. Reilly
Eileen M. Teichert, Esq. Southern California Edison Company
Supervising Deputy City Attorney San Onofre Nuclear Generating Station
City of Riverside P.O. Box 128
3900 Main Street San Clemente, CA 92674-0128
Riverside, CA 92522
Daniel P. Breig
Ray W. Waldo Southern California Edison Company
Southern California Edison Company San Onofre Nuclear Generating Station
San Onofre Nuclear Generating Station P.O. Box 128
P.O. Box 128 San Clemente, CA 92674-0128
San Clemente, CA 92674-0128
A. Edward Scherer
David Spath, Chief Southern California Edison Company
Division of Drinking Water and San Onofre Nuclear Generating Station
Environmental Management P.O. Box 128
California Department of Health Services San Clemente, CA 92674-0128
P.O. Box 942732
Sacramento, CA 94234-7320 Brian Katz
Southern California Edison Company
Michael R. Olson San Onofre Nuclear Generating Station
San Onofre Liaison P.O. Box 128
San Diego Gas & Electric Company San Clemente, CA 92674-0128
P.O. Box 1831
San Diego, CA 92112-4150 Aubrey Godwin, Director
Arizona Radiation Regulatory Agency
Director, Radiologic Health Branch 4814 South 40th Street
State Department of Health Services Phoenix, AZ 85040
P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414 Karen K. Beckley, Supervisor
Radiological Health Section
Mayor Nevada State Health Division
City of San Clemente Bureau of Health Protection Services
100 Avenida Presidio 1179 Fairview Drive, Suite 102
San Clemente, CA 92672 Carson City, NV 89701-5405
Southern California Edison Co. -5-
Gary Butner
Radiation Control Program Director
1500 Capitol, MS7610
Sacramento, CA 95814
Dane Finerfrock, Director
Department of Environmental Quality
P.O. Box 144850
168 North 1950 West
Salt Lake City, Utah 84114-4850
The Honorable Christine Kehoe
California Senate District 39
State Capitol, Room 3086
Sacramento, CA 95814
Southern California Edison Co. -6-
bcc w/enclosure (via e-mail distribution):
LDWert
DBSpitzberg
MVasquez
MSHaire
KFuller-Smith
JCShepherd, NMSS/DWMEP/DD
CCOsterholtz, SRI
RJEvans
BASchlapper
KEGardin
FCDB File
SUNSI Review Completed: RJE ADAMS: O Yes G No Initials: RJE
O Publicly Available G Non-Publicly Available G Sensitive O Non-Sensitive
DOCUMENT NAME: s:\dnms\!fcdb\!bas2\6050206011-so1.wpd final r:\_so1\2006
RIV:DNMS:FCDB RIV:DNMS:FCDB RIV:ACES C:FCDB D:DNMS
BSAlferink RJEvans via email MVasquez DBSpitzberg LDWert
/RA/ /RA BSAlferink /RA/ /RA JVEverett for/ /RA/
for/
06/27/06 06/27/06 06/28/06 06/28 /06 07/05 /06
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No: 050-00206
License No: DPR-13
Report No: 050-00206/06-011
Licensee: Southern California Edison Co.
P.O. Box 128
San Clemente, California 92674
Facility: San Onofre Nuclear Generating Station, Unit 1
Location: San Clemente, California
Dates: May 8 - 11, 2006 (onsite)
May 15 - June 26, 2006 (RIV Office followup)
Inspectors: Robert J. Evans, P.E., C.H.P., Senior Health Physicist
Fuel Cycle & Decommissioning Branch
Beth (Schlapper) Alferink, Health Physicist
Fuel Cycle & Decommissioning Branch
Approved By: D. Blair Spitzberg, Ph.D., Chief
Fuel Cycle & Decommissioning Branch
Attachment: Supplemental Inspection Information
-2-
EXECUTIVE SUMMARY
San Onofre Nuclear Generating Station, Unit 1
NRC Inspection Report 050-00206/06-011
This inspection was a routine, announced inspection of decommissioning activities being
conducted at San Onofre Nuclear Generating Station, Unit 1 facility. Areas inspected included
safety reviews, design changes, and modifications; self-assessments, auditing, and corrective
action; decommissioning performance and status review; occupational radiation exposure; and
solid radioactive waste management and transportation of radioactive materials.
Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
- The licensees safety review and design change program was in compliance with
10 CFR 50.59 requirements (Section 1).
Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors
- The licensee conducted self-assessments and audits in accordance with quality
assurance program requirements (Section 2).
Decommissioning Performance and Status Review at Permanently Shutdown Reactors
- The licensee was controlling the radiologically restricted area in accordance with
regulatory requirements. The licensee took actions to increase the efficiency of
containment demolition work including installation of a material handling system and use
of super-sacks (Section 3).
Occupational Radiation Exposure
- The licensee had an occupational exposure monitoring program that effectively
monitored internal and external doses to radiation. No individual exceeded the
regulatory limit for total effective dose equivalent exposures during 2005. The licensees
as low as reasonably achievable (ALARA) program was determined to be effective
(Section 4).
Transportation of Radioactive Materials
- The inspectors reviewed the circumstances associated with the leaking LSA-I bulk liquid
radioactive waste shipment transported from SONGS-1 to the Energy Solutions, Clive,
Utah facility reported on February 23, 2006. Three apparent violations of NRC and U.S.
Department of Transportation regulations were identified (Section 5).
-3-
Report Details
Summary of Plant Status
San Onofre Nuclear Generating Station, Unit 1 was permanently shut down during November
1992 and was permanently defueled by March 1993. The unit remained in SAFSTOR until
June 1999, when decommissioning was initiated. At the time of this inspection, the licensee
was conducting decommissioning activities under the DECON option as stated in its Post
Shutdown Decommissioning Activities Report dated December 15, 1998. DECON is defined as
the immediate removal and disposal of all radioactivity in excess of levels which would permit
the release of the facility for unrestricted use.
Work completed since the previous inspection included segmentation and removal of the three
hold-up tanks, removal and disposal of spent fuel pool and component cooling water system
support equipment, removal and disposal of components from the radwaste building,
installation and testing of the containment material handling system, and backfilling and
compacting of soil in the former turbine building area.
Work in progress during the inspection included demolition and removal of concrete from within
the containment sphere, removal of the spent fuel pool liner, removal of remaining equipment in
the lower level of the radwaste building, decontamination of the radwaste building floors, and
installation of electrical and instrumentation connections for the new yard sump. Equipment still
in service included two building fans, two radiation monitors and one dilution pump. Further,
one temporary dilution saltwater pump remained in service to provide dilution flow for any future
liquid discharges to the environment.
Activities planned for the near future include placing the new yard sump into service and
implementing Phase II dewatering operations. Phase II dewatering includes three dewatering
wells to support demolition of the radwaste and spent fuel buildings. The Phase II dewatering
flow rate is designed to be within the capacity of the new sump, approximately 2600 gpm.
1 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown
Reactors (37801)
1.1 Inspection Scope
The purpose of this portion of the inspection was to ascertain whether design changes,
tests, experiments, and modifications were effectively reviewed, conducted, managed,
and controlled during plant decommissioning in accordance with 10 CFR 50.59.
1.2 Observations and Findings
Regulation 10 CFR 50.59 addresses the change control process, a process used by the
licensee to determine if a proposed change to the facility, procedures, tests, or
experiments is subject to a license amendment and NRC approval. The process is
implemented through site procedure SO123-XV-44, "10 CFR 50.59 and 72.48
Program." This procedure provided instructions for both initial screening and
subsequent full evaluation, if necessary, of facility or procedure changes to confirm if the
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licensee can implement these changes without NRC approval. The program was a
common program for the two operating units and the decommissioning unit.
The inspectors reviewed randomly selected 10 CFR 50.59 screens of various facility
changes and found that all screens had been completed in accordance with procedural
requirements. The screens were independently reviewed by a person other than the
preparer. The inspectors found that the screens provided sufficient summary
information to explain what was being changed and why. Furthermore, the responses to
the screening criteria adequately addressed the criteria questions from a technical
perspective. No full 10 CFR 50.59 evaluations had been performed for Unit 1 changes
since the last inspection, and the inspectors did not identify any 10 CFR 50.59 screens
that should have been processed as full evaluations.
The inspectors noted that the licensee was considering the submittal of a license
amendment to decommission and free-release the off-shore cooling water system prior
to the 10 CFR Part 50 license termination. The inspectors discussed the proposed
action with the licensee, including the timetable for submittal of the radiological survey
plan, license amendment package, and supporting documentation to the NRC. The
review of any proposed change to the license or partial site release will be conducted by
the NRC following formal submittal of the survey plan or license amendment to the
NRC.
1.3 Conclusions
The licensees safety review and design change program was in compliance with
10 CFR 50.59 requirements.
2 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown
Reactors (40801)
2.1 Inspection Scope
The objective of this portion of the inspection was to evaluate the effectiveness of
licensee controls in identifying, resolving, and preventing issues that degrade safety or
the quality of decommissioning.
2.2 Observations and Findings
The licensee conducted several different types of self-assessments to help to ensure
compliance with regulatory requirements and license conditions. The self-assessments
included use of onsite review committees, internal reports, and leadership observations.
The requirements for some self-assessments are provided in the Quality Assurance
(QA) Program Topical Report SCE-1-A, Amendment 22.
The Nuclear Safety Group provided independent review of selected activities and is
required by Section 17.2.20.4 of the QA Program Topical Report. The Nuclear Safety
Groups quarterly reports for the third and fourth quarters of 2005 were reviewed during
the inspection. Unit 1 decommissioning activities reviewed by the Nuclear Safety Group
-5-
included conduct of QA surveillances and compliance with 10 CFR 50.59 requirements.
No new potential nuclear safety hazards were identified by the committee.
Routine QA audits are required by Section 17.2.18.2 of the QA Program Topical Report.
Program areas audited on a biennial basis included Unit 1 license compliance, quality
assurance programs, training, corrective action programs, and fire protection. Several
recent program audits and surveillances were reviewed, including surveillances of the
health physics program. The licensee was found to be conducting these reviews in
accordance with QA program requirements, and these reviews provided useful
information to licensee management.
The inspectors reviewed the 2006 master audit schedule, and compared the schedule to
the required audits specified in the applicable site procedure. All required audits and the
audit frequencies were correctly implemented into the 2006 master schedule. In other
words, all QA audits had been scheduled and were being completed at the required
frequency.
Unit 1 decommissioning project self-assessment reports were developed and issued
quarterly. The inspectors reviewed the reports for the fourth quarter of 2005 and the
first quarter of 2006. The reports provided critical analyses of performance indicators
and trends. The reports documented a reduction in the number of incidents caused by
personnel error as a positive trend. Areas for improvement, as noted in the reports,
included delays in selected decommissioning projects. In the past few months, the
licensee took specific actions to address the delay in the containment demolition work
schedule. These actions appear to be successful, and the licensee currently expects to
meet the August 2006 projection completion deadline.
The licensee used leadership observations to provide direct oversight of
decommissioning activities. The licensee believed that the leadership observation data
could be used as a tool for early identification of potentially unsafe behavior trends. The
inspectors observed a licensee representative conducting a leadership observation
during the inspection. The work being observed was the handling and loading of
radioactive material into railcars for shipment to at an out-of-state disposal site. The
leadership observation included personnel safety, rigging and health physics activities.
The observations were documented in two Leadership Observation Program reports.
2.3 Conclusions
The licensee conducted self-assessments and audits in accordance with QA program
requirements.
-6-
3 Decommissioning Performance and Status Review at Permanently Shutdown
Reactors (71801)
3.1 Inspection Scope
The inspectors evaluated whether the licensee and its contracted workforce were
conducting decommissioning activities in accordance with license and regulatory
requirements.
3.2 Observations and Findings
a. Site Tours/Control of Decommissioning Activities
The inspectors conducted tours of the Unit 1 facility to observe radiological area
postings and boundaries. Access to the restricted and contaminated areas was
controlled by radiation caution signs, barricades, boundary lines, locked doors, and
locked gates. Radiological boundaries were well defined and postings were up-to-date
in all areas.
The inspectors conducted independent radiological surveys in the radiologically
restricted area using a Ludlum Model 2401-P survey meter (NRC No. 21190G,
calibration due date 09/23/06). No abnormal radiological survey results were observed,
and all ambient gamma exposure rate measurements were in agreement with posted
radiation levels.
Recently, the licensee drained about 70 gallons of residual liquid from the bottom of the
spent fuel pool. The liquid was drained into 55-gallon drums and analyzed for
radioactive constituents. Radioactive cobalt-60 and cesium-134 and -137 were
identified in the liquid. During the inspection, the liquid wastes were still being stored in
the Unit 1 restricted area. The licensee has not formally decided how to dispose of the
liquid. The licensee had the option of shipping to a waste processor or solidifying and
shipping the resulting solid to an offsite disposal site.
Work in progress during the inspection included the physical removal of equipment.
Removal of the steel spent fuel pool liner was in progress. Most of the spent fuel pool
cooling and cleanup system had been removed with the exception of some system
filters. In summary, the licensee continued to make progress in decommissioning of the
Unit 1 site.
b. Demolition of Containment
In recent months, the licensee experienced delays with the demolition of containment.
The licensee addressed the delays by changing primary contractors, installing a material
handling system, and using super-sacks for loading of concrete debris. Further, the
licensee added a second work shift in an effort to reduce the scheduling delay.
The containment debris consists of concrete rubble and metal waste. The licensee
recently installed a material handling system to facilitate removal of debris from the
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containment sphere. During March 2006, the licensee began using 22,000-pound
capacity super-sacks for concrete rubble. The licensee continued to use intermodal
containers for the metal debris. Heavy equipment was used to demolish the
containment interior. The debris was loaded into either super-sacks or intermodals.
The inspectors observed the licensee conducting containment demolition and loading of
debris into transport containers. The licensee conducted these operations in an orderly
fashion with an emphasis on safety. The material handling system was used to
efficiently move the super-sacks and intermodals into and out of containment. Once
removed from containment, the debris in super-sacks was loaded directly into rail cars
for shipment to a waste disposal facility located in Utah. Intermodals were loaded on rail
cars or shipped to Utah via truck.
3.3 Conclusions
The licensee was controlling the radiologically restricted area in accordance with
regulatory requirements. The licensee took actions to increase the efficiency of
containment demolition work including installation of a material handling system and use
of super-sacks.
4 Occupational Radiation Exposure (83750)
4.1 Inspection Scope
The inspectors reviewed occupational radiation exposures for calendar year 2005 to
verify whether they met the limits specified in 10 CFR Part 20. This review focused on
the licensees internal and external occupational radiation exposure monitoring
programs as well as the ALARA program.
4.2 Observations and Findings
Occupational exposures consisted of both external and internal exposures. To measure
external exposures, plant personnel entering the radiologically restricted areas were
assigned both thermoluminescent dosimeters (TLDs) and direct reading electronic
dosimeters. The licensee maintained records of external exposures based on electronic
dosimeters until the TLD results were available. Whole body counting and in vitro
bioassays were used to detect the presence of radioactive material in the body. An
internal exposure assessment was conducted if a whole body count or a bioassay
identified internal deposition of radioactive material. Internal doses, if any, were
assigned as part of the internal exposure assessment process.
The inspectors reviewed the Unit 1 occupational exposure records for 2005. The
licensee issued dosimetry to measure for both gamma and neutron doses during 2005.
Neutron doses were anticipated because of spent fuel handling operations.
During 2005, 1591 TLDs were issued to measure gamma doses, down slightly from
2004 (1623 TLDs). Of that number, 198 individuals received a measurable gamma
dose. The combined total effective dose equivalent for all individuals with a measurable
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gamma dose was 20.624 person-rems, up from 2004 (14 person-rems) and down from
2003 (34 person-rems). In addition, workers were monitored for neutron doses. During
2005, 30 individuals received a measurable neutron dose. The total neutron dose was
0.884 person-rems, slightly lower than the collective neutron dose for 2004
(1.168 person-rems).
During 2005, the highest total effective dose equivalent to an individual working in Unit 1
was 0.63 rems, up from 2004 (0.494 rems). The highest neutron dose for 2005 was
0.059 rems. No individual exceeded the regulatory limit of 5 rems. The reduction in
collective doses was a result of a reduction in the source term (amount of radioactive
material present in Unit 1) and improvements in both job planning and ALARA practices.
During 2005, there were four personnel contamination events. None of these
contamination events resulted in assignment of internal doses to an individual.
Therefore, there were no internal exposures to Unit 1 personnel in 2005, down from four
individuals in 2004.
The inspectors reviewed the licensees ALARA program. Overall, the licensee had a
strong ALARA program in place for Unit 1. Performance indicators were tracked and
evaluated, including ALARA exposure goals. The exposure goal for 2005 was 21.5
person-rems. The ALARA goal for 2006 is 25.5 person-rems based on the work
activities planned for the calender year. The three work projects with the highest
potential for exposure are fuel storage building liner removal, radwaste systems and
remediation and health physics functions.
The inspectors noted that the licensee conducted an assessment of electronic
dosimeter results versus TLD results. The licensee conducted this assessment using
industry-sponsored guidance.
4.3 Conclusions
The licensee had an occupational exposure monitoring program that effectively
monitored internal and external doses to radiation. No individual exceeded the
regulatory limit for total effective dose equivalent exposures during 2005. The licensees
ALARA program was determined to be effective.
5 Transportation of Radioactive Materials (86750)
5.1 Inspection Scope
The purpose of this portion of the inspection effort was to followup on the NRC Event
Notification regarding the leaking low specific activity (LSA)-1 bulk liquid radioactive
waste shipment reported on February 23, 2006, and to determine whether the licensee
properly packaged and shipped the radioactive materials involved and to determine
whether transportation activities were conducted in compliance with applicable NRC and
U.S. Department of Transportation regulations.
5.2 Observations and Findings
-9-
As a followup to an NRC Event Notification (EN 42370) reported on February 23,
2006, the inspectors reviewed the circumstances and events surrounding the leaking
LSA-1 bulk liquid radioactive waste shipment from the SONGS facility to Energy
Solutions of Clive, Utah, for processing and disposal.
During the Unit 1 decommissioning process, SONGS generated radioactive liquids that
required offsite treatment and disposal. SONGS contracted with Energy Solutions of
Clive, Utah, to provide a portable tank that met the specifications of 49 CFR 172.101
under the proper shipping name and description of, Radioactive material, low specific
activity, N.O.S. Column #7 special provisions T5. The tank supplied was documented
by Energy Solutions to meet these requirements including all pressure testing. Energy
Solutions also subcontracted with Triad Trucking as the carrier of the shipment from the
SONGS facility to Energy Solutions.
5.2.a Summary of Event
On February 22, 2006, SONGS loaded LSA-I bulk liquid radioactive waste into two
intermodal (IM) portable tanks, each tank having a capacity of 6,340 gallons. Triad
Trucking, the carrier, requested that SONGS load the portable tanks with 4500 gallons
of liquid because of a concern, by the carrier, that if loaded to greater than 4500 gallons,
the truck would exceed applicable DOT weight restrictions.
10 CFR 71.5(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, shall comply with the
applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180,
and 390 through 397, appropriate to the mode of transport. In particular, 49 CFR
173.32(f)(5) requires, in part, that an IM portable tank having a volume greater than
7,500 L (1,980 gallons) may not be loaded to a filling density of more than 20% and less
than 80% by volume. (The intermodal portable tanks did not contain partitions or surge
plates which would make this requirement not applicable.) However, SONGS loaded
each of the two IM portable tanks with 4,500.7 gallons (17.037 m3). Based on the 6,340
gallon capacity of each tank, this represents a filling density of 71% by volume which
does not comply with the 80% filling density specified in 49 CFR 173.32(f)(5). This
failure was identified as an apparent violation of 10 CFR 71.5(a) and 49 CFR 173.32
(APV 050-00206/06-02).
The driver of one of the two shipments (later to be found leaking) performed walk-
around inspections of the truck and portable tank twice at vehicle scales in Ontario,
California and at a fuel stop north of Las Vegas, Nevada, as required by 49 CFR 392.9.
The driver did not observe any leakage of the package during these inspections. On
February 22, 2006 at 10:00PM (MST), at the truck stop in Parowan, Utah, the driver
again performed the walk-around inspection and observed wetness beneath the truck.
The driver then moved the truck from the gasoline pumping area to a remote area of the
parking lot. The driver notified the carriers terminal manager who arrived onsite at
1:00AM (MST) on February 23, 2006. The manager identified the location of the leak as
the tank discharge compartment, removed the Energy Solutions security seal, and
stopped the leak by releasing pressure on the tank. The terminal manager contacted
Energy Solutions and the SONGS Fire Department (the designated emergency contact
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on the shipping papers) at 3:30AM (PST) on February 23, 2006. No problems were
reported with the second portable tank shipment.
In order to stop the leak from the portable tank, the terminal manager had to climb the
access ladders to the top of the tank and open the top discharge valve compartment.
These areas had liquid low-level radioactive waste present on them. Because of this,
there was personnel contamination on the terminal manager during the initial response
to stop the leak of radioactive liquid from the tanker. The personnel contamination was
limited to the managers clothing and not the underlying skin.
During transport activities, the concentration of radioactive material permitted in an
LSA-I bulk liquid package is so low that were leakage to occur, it is highly unlikely to
result in a significant radiation exposure to a member of the public. However, in this
case the leak resulted in some low-level contamination that could be safely removed. At
12:50 PM (PST) on February 23, 2006, SONGS staff arrived at the truck stop to perform
radiological surveys. The surveys identified two distinct areas of low-level contamination
on the ground, one at the gasoline pumps and the second at the area where the truck
had been relocated. Both areas were roped off and subsequently decontaminated to
background levels. SONGS estimated that approximately 5-gallons of liquid or
approximately 0.08 milliCuries total activity leaked from the portable tank.
On February 24, 2006, SONGS staff commenced remediation of the truck stop,
including removal of asphalt and underlying soil. The asphalt and soil was disposed of
as low-level waste at Energy Solutions. The highest level of contamination located on
the ground in the remote parking area was 33,000 net-counts per minute (, ) using
direct frisk; the measured dose rate in this same area was 0.4 mrem/hr at 1-foot from
ground surface or 1 mrem/hr on contact with the ground surface. This measured dose
rate is less than the radiation dose limit from external sources for individual members of
the public of 2 mrem/hr in any unrestricted area as specified in 10 CFR 20.1301(a)(2).
On February 24, 2006, SONGS and the Utah Division of Radiation Control performed
direct frisk surveys of the highway exit ramp prior to the truck stop, and the stop sign
area located on this exit ramp. This area was deemed the area with the highest
potential for contamination prior to the truck stop. These surveys showed no detectable
activity above background. Also, on February 24, 2006, the portable tank was
decontaminated and sent to Energy Solutions without incident following removal of the
valve that was determined to be leaking. The valve was replaced with a blind flange,
and the original valve and bolts were packaged inside the discharge pump cover and
security sealed by SONGS personnel. In addition, Energy Solutions, the waste disposal
site, indicated that the volume of liquid removed from the transportation package when it
was emptied was in close agreement with the initial volume shipped, further indicating
that the leakage volume was small. The NRC believes that this information, combined
with the prior vehicle checks showing no leakage in California and Nevada, provides a
sufficient basis to conclude that little or no leakage occurred prior to the trucks arrival at
the truck stop in Parowan, Utah.
Remediation was completed by SONGS on February 26, 2006 and the Utah Division of
Radiation Control completed a sample and survey review on February 27, 2006.
Backfilling, compaction and concrete pour at the truck stop were completed on March 1,
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2006.
10 CFR 71.5(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, shall comply with the
applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180,
and 390 through 397, appropriate to the mode of transport. In particular,
49 CFR 173.24 (b) requires, in part, that each package used for the shipment of
hazardous materials be designed, constructed, maintained, filled, its contents so limited,
and closed, so that under conditions normally incident to transportation that there will be
no identifiable release of hazardous materials to the environment. SONGS failed to use
a package that was maintained, filled and closed, so that under conditions normally
incident to transportation there was no identifiable release of hazardous materials to the
environment. This failure was identified as an apparent violation of 10 CFR 71.5(a) and
49 CFR 173.24 (APV 050-00206/06-03).
5.2.b Package Description
The package used for this LSA-1 bulk liquid radioactive waste shipment was a
Eurotainer LOGU 164060-1 with no bottom penetrations procured by SONGS through a
contract with Energy Solutions. Although the portable tank was originally manufactured
with bottom openings, these had been previously welded shut per DOT instructions and
the pressure test was performed on February 5, 2005 following these bottom welds.
The next pressure test was due May 19, 2006. The Eurotainer LOGU 164060-1 was
designed with a standpipe that extended from the discharge valve to the bottom of the
tank. Compressed air at 25 psi is used to remove the contents of the tank. Energy
Solutions maintains two different designs of discharge valves on the Eurotainers at the
Clive, Utah, facility with different lengths of fasteners, dependent on the design. To
release the containers for unrestricted use after a shipment, the containers must be
decontaminated. Decontamination requires disassembly of the valve and removal of the
valve and standpipe from the tank. Energy Solutions records indicate that the LOGU
164060-1 tank was released to the unrestricted area of the site in September 2005. No
additional pressure or leak tests were performed.
5.2.c Cause of Event
SONGS-1 performed a root cause evaluation, with input from Energy Solutions, for the
valve assembly pressure boundary issue. Energy Solutions determined that at some
time following the last unloading of material at the Clive facility that occurred on April 25,
2005, two of the bolts for the discharge valve assembly at the top of the tank were
replaced with longer bolts (3.5 inch). The longer bolts bottomed out on the standpipe
mount, resulting in a condition such that after the tank was filled with liquid, there was
leakage at the valve body/gasket interface after the slight (<3 psi) atmospheric pressure
change from sea level at the SONGS facility to approximately 6,000 feet at the
Parowan, Utah, truck stop. The cause of the event was a seal deficiency as a result of
using bolts that were not acceptable per the design drawings provided by the tank
manufacturer, Eurotainer. Namely, two 3 inch bolts, the correct size, and two 3.5 inch
bolts (incorrect size) were used to secure the valve to the standpipe. The 3.5 inch bolts
bottomed out in the valve assembly when torque was applied, and therefore did not
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provide an adequate seal for the gasket.
10 CFR 71.5(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, shall comply with the
applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180,
and 390 through 397, appropriate to the mode of transport. In particular,
49 CFR 173.475 requires, in part, that before each shipment of any Class 7 (radioactive)
materials package, the offeror must ensure by examination or appropriate tests, that the
packaging is proper for the contents to be shipped. In addition, 49 CFR 173.475(f)
requires, in part, that each closure, valve, or other opening of the containment system
through which the radioactive content might escape is properly closed and sealed. Prior
to the shipment of liquid radioactive LSA material on February 22, 2006, SONGS failed
to ensure by examination or appropriate tests that the top discharge valve of a package
containing licensed material was properly closed and sealed. As described in Section
5.2.d below, contractor performance deficiencies contributed to the event. The gasket
was not properly seated due to incorrect bolt sizes, and due to the incorrect bolt sizes on
the top discharge valve assembly, the package was therefore not properly closed and
sealed. This failure was identified as an apparent violation of 10 CFR 71.5(a) and
49 CFR 173.475 (APV 050-00206/06-01).
5.2.d Contractor Performance Issues
During NRCs review of this transportation incident, the following potential performance
deficiencies were identified, associated with Energy Solutions (Energy Solutions is not
an NRC licensee):
SONGS personnel were not informed that decontamination and maintenance activities
were performed on the Eurotainer LOGU 164060-1 subsequent to the pressure test
performed on February 5, 2005. Any removal of the standpipe or valve assembly during
decontamination and maintenance would invalidate the pressure and leak tests
performed on the tank and would require retesting to verify pressure boundary integrity.
The Energy Solutions root cause evaluation states that there were four containers
scheduled for decontamination and subsequent unrestricted release in September 2005.
The containers, including the LOGO 164060-1, were removed from the restricted area
on September 30, 2005.
The Eurotainer LOGU 164060-1 supplied to SONGS, as part of the contracting process,
required the vendor to provide a portable tank that met the specifications of
49 CFR 172.101 under the proper shipping name and description of, Radioactive
material, low specific activity, N.O.S. Column #7 special provisions T5. The tank
supplied was documented by Energy Solutions to meet these requirements including all
pressure testing. The Eurotainer LOGU 164060-1 supplied to SONGS was not capable
of fulfilling its designed function within the contract specifications and requirements.
The substitution of bolts is not clarified in the Energy Solutions root cause evaluation,
but the evaluation does state that the tank did not leak during its last use. Energy
Solutions security sealed the tank prior to it leaving the Clive, UT facility, and the seal
was intact when it arrived at the SONGS facility. SONGS retained Energy Solutions
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personnel to perform inspections on the container, and therefore did not remove the
security seal for the discharge valve compartment. This security seal was not removed
until Parowan, Utah, when it was discovered that the tank was leaking. The valve and
associated bolts were bagged at the truck stop by SONGS personnel and placed within
the discharge valve assembly cover. A security seal was then placed on this cover by
SONGS personnel prior to the tank departing Parowan, Utah, for the Energy Solutions
facility in Clive, Utah. The Energy Solutions root cause analysis proposed corrective
actions included disassembly of all containers at the Clive facility to verify bolt
size/length configuration in accordance with the manufacturers drawings and perform
pressure tests on the tanks. This root cause analysis was provided to SONGS for
inclusion in their root cause evaluation for the package pressure boundary issue.
5.3 Conclusions
Three apparent violations of NRC and DOT regulations were identified while reviewing
the leaking LSA-I bulk liquid radioactive waste shipment transported from SONGS-1 to
Energy Solutions of Clive, UT that occurred February 22 to 23, 2006. The three
apparent violations are summarized below.
Although it was determined that actual health and safety consequences to the public
due to the leaking tank were minimal and there was limited disruption of the use of the
truck stop in Parowan, Utah, due to the event, the NRC and U.S. Department of
Transportation are concerned about the breach of the package and the subsequent loss
of contents in the public right-of-way. The regulations in 10 CFR 71.5 and 49 CFR are
in place to ensure that there are not performance deficiencies that could lead to a
breach of package and an uncontrolled loss of contents when shipping liquid radioactive
waste.
10 CFR 71.5(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, shall comply with the
applicable requirements of the DOT regulations in 49 CFR parts 107, 171 through 180,
and 390 through 397, appropriate to the mode of transport.
1. 49 CFR 173.475 requires, in part, that before each shipment of any Class 7
(radioactive) materials package, the offeror must ensure by examination or
appropriate tests, that the packaging is proper for the contents to be shipped. In
addition, 49 CFR 173.475(f) requires, in part, that each closure, valve, or other
opening of the containment system through which the radioactive content might
escape is properly closed and sealed.
Prior to the shipment of liquid radioactive LSA material on February 22, 2006,
SONGS did not ensure by examination or appropriate tests that the top
discharge valve of a package containing licensed material was properly closed
and sealed. The gasket was not properly seated due to incorrect bolt sizes, and
due to the incorrect bolt sizes on the top discharge valve assembly, the package
was therefore not properly closed and sealed. This failure was identified as an
apparent violation of 10 CFR 71.5(a) and 49 CFR 173.475
(APV 050-00206/06-01).
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2. 49 CFR 173.32(f)(5) requires, in part, that an IM portable tank having a volume
greater than 7,500 L (1,980 gallons) may not be loaded to a filling density of
more than 20% and less than 80% by volume.
On February 22, 2006, the licensee failed to load two IM portable tanks with a
volume greater than 7,500 L to a filling density of more than 20% and less than
80% by volume and offered these portable tanks for shipment. Specifically, the
licensee loaded two IM portable tanks with a capacity of 6,340 gallons with
4,500.7 gallons (17.037m3) for a filling density of 71% by volume. This failure
was identified as an apparent violation of 10 CFR 71.5(a) and 49 CFR 173.32
(APV 050-00206/06-02).
3. 49 CFR 173.24 (b) requires, in part, that each package used for the shipment of
hazardous materials be designed, constructed, maintained, filled, its contents so
limited, and closed, so that under conditions normally incident to transportation
that there will be no identifiable release of hazardous materials to the
environment.
On February 22, 2006, SONGS used a package that was not maintained, filled
and closed, so that under conditions normally incident to transportation that there
will be no identifiable release of hazardous materials to the environment. On
February 23, 2006, SONGS was notified by the carrier that under conditions
normally incident to transportation, that there was a leak of hazardous materials
to the environment. This failure was identified as an apparent violation of
10 CFR 71.5(a) and 49 CFR 173.24 (APV 050-00206/06-03).
6 Exit Meeting Summary
The inspectors presented the preliminary inspection results to members of licensee
management at the exit meeting on May 11, 2006. The final exit briefing was presented
telephonically to the licensee on June 26, 2006. The licensee did not identify as
proprietary any information provided to, or reviewed by, the inspectors.
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
D. Axline, Licensing Engineer, Nuclear Regulatory Affairs
D. Breig, Station Manager
J. Brooks, Engineer, Unit 1 Health Physics
B. Katz, Vice President, Nuclear Oversight and Regulatory Affairs
M. Kirby, Unit 1 Operations Supervisor
C. McAndrews, Manager, Nuclear Oversight
D. Pilmer, Project Manager, Nuclear Regulatory Affairs
A. Scherer, Manager, Nuclear Regulatory Affairs
J. Sills, Project Manager, Unit 1 Health Physics
S. Enright, LLRW Manager, Unit 1 Decommissioning
INSPECTION PROCEDURES USED
37801 Safety Reviews, Design Changes, and Modifications at Permanently Shutdown Reactors
40801 Self-Assessment, Auditing, and Corrective Action at Permanently Shutdown Reactors
71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors
83750 Occupational Radiation Exposure
86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials
ITEMS OPENED AND CLOSED
Opened
APV 050-00206/06-01 An apparent violation involving the licensees failure to ensure by
examination or appropriate tests that the top discharge valve of a
package containing licensed material was properly closed and
sealed.
APV 050-00206/06-02 An apparent violation involving the licensees failure to load two IM
portable tanks with a volume greater than 7,500 L to a filling
density of more than 20% and less than 80% by volume and offer
these portable tanks for shipment.
APV 050-00206/06-03 An apparent violation involving the licensee using a package that
was not maintained, filled and closed, so that under conditions
normally incident to transportation that there was no identifiable
release of hazardous materials to the environment.
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Closed
None
Discussed
None
LIST OF ACRONYMS
ALARA As Low As Reasonably Achievable
APV Apparent Violation
CFR Code of Federal Regulations
cpm counts per minute
DOT United States Department of Transportation
dpm/100cm2 disintegrations per minute per 100-square centimeters
IM intermodal
LSA Low Specific Activity
MST Mountain Standard Time
PST Pacific Standard Time
QA quality assurance
TLDs thermoluminescent dosimeters