ML063110067
| ML063110067 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/07/2006 |
| From: | Blough A Division of Reactor Safety I |
| To: | Ted Sullivan Entergy Nuclear Operations |
| References | |
| EA-06-253 IR-06-011 | |
| Download: ML063110067 (11) | |
See also: IR 05000271/2006011
Text
November 7, 2006
Mr. Theodore A. Sullivan
Site Vice President
Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station
320 Governor Hunt Road
Vernon, VT 05354
SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION
NRC INSPECTION REPORT 05000271/2006011
Dear Mr. Sullivan:
On October 6, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Vermont Yankee Nuclear Power Station. The enclosed report documents the inspection
findings which were discussed on October 6, 2006, with members of your staff.
The inspection examined 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 inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report discusses one finding that appears to have a low to moderate safety significance.
As described in Section 2PS2 of this report, the finding involves an August 31, 2006 radioactive
material shipment from your facility, via an exclusive-use open transport vehicle, that did not
conform to the applicable Department of Transportation (DOT) regulatory requirements when it
arrived at the shipping destination. Specifically, upon receipt, the external radiation exposure
rate on the surface of the affected package was determined to exceed DOTs regulatory
specification. The apparent cause was ineffective decontamination of the package contents,
and an insufficient radiological survey to assure that, under conditions normally incident to
transport, the package would conform with DOTs radiation level limits specified in 49 CFR
173.441(a).
Preliminarily, we consider that this is a self-revealing finding having a low to moderate safety
significance because the external package dose rate was greater than two, but less than five
times the radiation level limitation specified in the DOT regulatory requirement. Though the
surface of the package was inaccessible to the public during transport, that aspect was
fortuitous and not the result of design or package preparation by the licensee. Additionally, the
condition had the potential to adversely affect personnel who would normally receive the
package or respond to an incident involving the package with the reasonable expectation that
the package conformed with DOT radiation limitations. Accordingly, the finding is considered
an apparent violation of NRC requirements specified by 10 CFR 71.5 and 49 CFR 173.441(a),
and is being considered for escalated enforcement action in accordance with the NRC
2
Enforcement Policy. The current policy is included on the NRCs website at
http://www.nrc.gov - select What We Do, Enforcement, then Enforcement Policy.
We believe that we have sufficient information to make a final significance determination for this
matter. However, before the NRC makes a final decision on this matter, we are providing you
an opportunity to (1) present to the NRC your perspectives on the facts and assumptions, used
by the NRC to arrive at the finding and its significance at a Regulatory Conference, or (2)
submit your position on the finding to the NRC in writing. If you request a Regulatory
Conference, it should be held within 30 days of the receipt of this letter and we encourage you
to submit supporting documentation at least one week prior to the conference in an effort to
make the conference more efficient and effective. If a Regulatory Conference is held, it will be
open for public observation and a press release will be issued to announce it. If you decide to
provide a written response in lieu of the Regulatory Conference, the submission should be sent
to the NRC within 30 days of the receipt of this letter.
Please contact John R. White at 610-337-5114 within 10 business days of the date of this letter
to notify the NRC of your intentions. If we have not heard from you within 10 days, we will
continue with our significance determination and enforcement decision; and you will be advised
by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for this inspection finding at this time. While this matter continues under NRC review,
the number and characterization of apparent violations described in the enclosed inspection
report may change.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of the NRC's document
system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA by M.Gamberoni acting for/
A. Randolph Blough, Director
Division of Reactor Safety
Docket No. 50-271
License No. DPR-28
Enclosure: Inspection Report No. 05000271/2006011
w/Attachment: Supplemental Information
Mr. Theodore A. Sullivan 3
cc w/encl:
M. R. Kansler, President, Entergy Nuclear Operations, Inc.
G. J. Taylor, Chief Executive Officer, Entergy Operations
J. T. Herron, Senior Vice President and Chief Operating Officer
C. Schwarz, Vice-President, Operations Support
O. Limpias, Vice President, Engineering
J. M. DeVincentis, Manager, Licensing, Vermont Yankee Nuclear Power Station
Operating Experience Coordinator, Vermont Yankee Nuclear Power Station
W. Maguire, General Manager, Plant Operations, Entergy Nuclear Operations, Inc.
N. Rademacher, Director NSA, Vermont Yankee Nuclear Power Station
J. F. McCann, Director, Licensing
C. D. Faison, Manager, Licensing
M. J. Colomb, Director of Oversight, Entergy Nuclear Operations, Inc.
T. C. McCullough, Assistant General Counsel, Entergy Nuclear Operations, Inc.
J. H. Sniezek, PWR SRC Consultant
M. D. Lyster, PWR SRC Consultant
S. Lousteau, Treasury Department, Entergy Services, Inc.
Administrator, Bureau of Radiological Health, State of New Hampshire
Chief, Safety Unit, Office of the Attorney General, Commonwealth of Mass.
J. E. Silberg, Pillsbury, Winthrop, Shaw, Pittman LLP
G. D. Bisbee, Esquire, Deputy Attorney General, Environmental Protection Bureau
J. Block, Esquire
J. P. Matteau, Executive Director, Windham Regional Commission
D. Katz, Citizens Awareness Network (CAN)
R. Shadis, New England Coalition Staff
G. Sachs, President/Staff Person, c/o Stopthesale
C. McCombs, Director, Commonwealth of Massachusetts, SLO Designee
State of New Hampshire, SLO Designee
State of Vermont, SLO Designee
Mr. Theodore A. Sullivan 4
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ROPreports@nrc.gov (All IRs)
Region I Docket Room (with concurrences)
C:\FileNet\ML063110067.wpd
SUNSI Review Complete: JRW (Reviewers Initials)
DOCUMENT NAME:
After declaring this document An Official Agency Record it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with
attachment/enclosure "N" = No copy
OFFICE RI/DRS RI/DRS RI/DRP RI/ENF RI/DRS
NAME JNoggle*/JRW for JWhite*/JRW RPowell*/RJP RSummers*/RJS ABlough/ARB
DATE 10/27/06 11/02/06 11/02/06 11/02/06 11/03/06
- See Previous Concurrence Page
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-271
Licensee No.: DPR-28
Report No.: 05000271/2006011
Licensee: Entergy Nuclear Operations, Inc.
Facility: Vermont Yankee Nuclear Power Station
Location: 320 Governor Hunt Road
Vernon, Vermont 05354-9766
Dates: September 6, 2006 through October 6, 2006
Inspectors: James D. Noggle, Senior Health Physicist, DRS
Approved by: John R. White, Chief
Plant Support Branch 2
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000271/2006011; 09/06/06 - 10/06/06; Vermont Yankee Nuclear Power Station;
Radioactive Material Processing and Transportation.
This report covered a one month period of inspection by a regional senior health physics
inspector. One potential White finding was identified. The significance of most findings is
indicated by their color (Green, White, Yellow, Red) using inspection Manual Chapter (IMC)
0609, Significance Determination Process (SDP). Findings for which the SDP does not apply
may be Green or be assigned a severity level after NRC management review. The NRC's
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Preliminary White: The inspector identified a self-revealing finding, involving a failure to
properly prepare and ship a package containing radioactive material in a manner that
assured, under conditions normally incident to transport, conformance with Department
of Transportation (DOT) radiation level limitations specified by 49 CFR 173.441(a), i.e.,
200 millirem per hour (mrem/h) on any external surface of the package. Accordingly,
the finding was also considered an apparent violation of the requirements of 10 CFR
71.5 and 49 CFR 173.441(a). The finding involved an August 31, 2006 radioactive
material shipment, via an exclusive-use open transport vehicle, that was determined to
have 820 mrem/h on the external surface of a package upon receipt at the shipping
destination. The licensee entered this performance deficiency in its corrective action
program; completed a root cause evaluation; and initiated corrective measures,
including various process improvements to prevent recurrence.
This finding is more than minor since it affected the Public Radiation Safety cornerstone,
and involved an occurrence in the licensees radioactive material transportation program
that was contrary to DOT regulations. Preliminarily, the significance of this finding is
considered as having low to moderate safety significance, since the radiation level was
greater than two times the limit (400 mrem/h), but less than five times the limit (1000
mrem/h) specified by the DOT regulatory requirement. Though the surface of the
package was inaccessible to the public during transport, that aspect was fortuitous and
not the result of design or package preparation by the licensee; and the condition had
the potential to adversely affect personnel who would normally receive the package or
respond to an incident involving the package, with a reasonable expectation that the
package conformed with DOT radiation limitations. This finding is documented within the
licensees corrective action system as CR-VTY-2006-02723. (Section 2PS2)
ii Enclosure
REPORT DETAILS
2. RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS2 Radioactive Materials Processing and Shipping (7112202)
a. Inspection Scope
This inspection was focused at reviewing the circumstances surrounding an August 31,
2006, radioactive material shipment from Entergys Vermont Yankee nuclear power
plant (Windham County, Vermont) to Pennsylvania Power and Lights Susquehanna
nuclear power plant (Luzerne County, Pennsylvania). The radioactive material shipment
(three packages via an exclusive-use vehicle) was received at Susquehanna on
September 1, 2006. Upon receipt, one of the packages, which contained contaminated
equipment (i.e, an Advance Crusher/Shearer), was found to have radiation levels on the
external surface (underside) in excess of the Department of Transportations radiation
limit for external surface of packages shipped by exclusive use vehicles, as specified in
49 CFR 173.441(a). Specifically, 49 CFR 173.441(a) limits the radiation level on
package surfaces to 200 millirem per hour (200 mrem/h). When received at
Susquehanna, the radiation level on the surface of one of the packages was measured
as 820 mrem/h.
On September 6-7, 2006, the inspector witnessed the as-received condition of the
Vermont Yankee shipment on the refueling floor at Susquehanna. The inspector
observed the conduct of radiological surveys of the package conducted by Vermont
Yankee and Susquehanna radiation protection personnel, and the radiological controls
implemented to open and examine the package contents (i.e., Advanced
Crusher/Shearer equipment). The inspector observed the efforts by the Susquehanna
and Vermont Yankee personnel to identify the source of the excessive radiation levels
on the package. In addition, the inspector reviewed shipping documentation, including
all receipt surveys conducted by Susquehanna personnel.
On October 2-6, 2006, the inspector examined the radioactive material shipping process
at the Vermont Yankee nuclear power plant, including review of Vermont Yankees
corrective action documentation and associated root cause analysis. The inspector also
observed the conduct of Vermont Yankees corrective action review board meeting that
was convened to review and approve the root cause analysis. In addition, the inspector
reviewed the conduct of activities associated with a radioactive material shipment in
order to ascertain the effectiveness of the licensees corrective actions that were
instituted in response to this occurrence.
Enclosure
2
The above inspection activities were conducted to verify that the licensees radioactive
material processing and transportation programs complied with the requirements of
10 CFR 20, 61, and 71; and Department of Transportation (DOT) regulations 49 CFR
170-189.
b. Findings
Introduction
The inspector identified a self-revealing finding involving Entergys (Vermont Yankee)
failure to properly prepare and ship a package containing radioactive material in a
manner that assured, under conditions normally incident to transport, conformance with
Department of Transportation (DOT) radiation level limitations specified by 49 CFR
173.441(a), i.e., 200 millirem per hour (mrem/h) on any external surface of the package.
When shipped from Vermont Yankee on August 31, 2006, the licensees radiological
surveys indicated that the package conformed with the DOT regulatory requirements.
However, when the shipment arrived at Susquehanna on September 1, 2006, the
maximum radiation dose rate on the external surface of the package was measured as
820 mrem/h.
Description
On August 31, 2006, a Low Specific Activity (LSA) shipment of a control rod drive
processing device, i.e., Advanced Crusher/Shearer, was packaged and shipped from
Entergys Vermont Yankee nuclear power plant (Windham County, Vermont) to
Pennsylvania Power and Lights Susquehanna nuclear power plant (Luzerne County,
Pennsylvania). Vermont Yankees final shipment surveys indicated the maximum dose
rate on any package surface to be 60 mrem/h. However, upon receipt at Susquehanna,
the package containing the Advanced Crusher/Shearer unit was surveyed and found to
have a radiation level on the underside (bottom) external surface of 820 mrem/h at
contact.
On September 6-7, 2006, under controlled conditions at Susquehanna, qualified
personnel opened the package containing the Advanced Crusher/Shearer unit to
determine the source of the high radiation level. The equipment was found to be
properly braced and secured, as required. Upon close examination, several small highly
radioactive pieces of debris were identified, including a small metal sliver (<1").
Additionally, several discrete radioactive particles were detected, though not visible.
Surveys indicated that the metal sliver exhibited a radiation level of about 800 mrem/h;
and the discrete radioactive particles exhibited radiation levels that ranged from 400 -
1400 mrem/h. The debris was found in a location in the package that coincided with the
external surface that indicated the 820 mrem/h radiation level. After removal of this
radioactive material, the external surface (bottom) of the package was re-surveyed by
the Susquehanna radiation protection technicians. A dose rate of about 60 mrem/h was
measured at the location, which confirmed that the loose debris was the likely cause of
the 820 mrem/h dose rate.
Enclosure
3
The detection of the highly radioactive debris indicated that Entergys efforts to
decontaminate the Advanced Crusher/Shearer unit prior to shipment were not
completely successful; and that radiological surveys, conducted to assure conformance
with the DOT regulatory requirements, were not sufficient for detecting highly radioactive
small particles that potentially could be redistributed within the package under conditions
normally incident to transport.
The inspector determined that in the configuration used to transport the package, the
bottom external surface of the package was not accessible to any member of the public.
However, it was noted that though redistribution of the material likely occurred as a
result of conditions normally incident to transport, it was fortuitous and not the result of
design or package preparation that the material was deposited in such manner that
effectively limited the potential for any public exposure. Further, it was determined that
the condition had the potential to adversely affect personnel who would normally receive
the package or respond to an incident involving the package with the reasonable
expectation that the package conformed with DOT radiation limitations.
Analysis
This matter was considered a performance deficiency, in that the failure to adequately
decontaminate and survey the Advanced Crusher/Shearer equipment prior to shipment
was within Entergys ability to foresee, correct, and should have been prevented,
particularly, since the phenomena of redistribution of highly radioactive particles during
transport of contaminated equipment is not uncommon. However, the matter had no
actual safety consequence, or impact on the NRCs ability to perform its regulatory
function; and there were no willful aspects associated with this finding.
This finding was considered more than minor since it is associated with the Public
Radiation Safety cornerstone attributes of the program and process relative to DOT
package radiation limits; and affected the cornerstone objective to ensure adequate
protection of the public from exposure to radioactive materials released into the public
domain. Application of Manual Chapter 0609, Appendix D, the Public Radiation Safety
Significance Determination Process is appropriate since the finding involved an
occurrence in the licensees radioactive material transportation program that was
contrary to DOT regulations, i.e., 49 CFR 173.441(a). This finding was documented
within the licensees corrective action system as CR-VTY-2006-02723.
Preliminarily, the significance of this finding is considered as having low to moderate
safety significance (White), since the radiation level determined on the external package
surface was greater than two times the limit (400 mrem/h), but less than five times the
limit (1000 mrem/h) specified by the DOT regulatory requirement. This determination is
also reinforced by the determination that, though the potential for public exposure was
limited during transportation, the condition had the potential to adversely affect personnel
who would normally receive the package or respond to an incident involving the package
with the reasonable expectation that the package conformed with DOT radiation
limitations.
Enclosure
4
Enforcement
Title 10 CFR 71.5, Transportation of licensed material, requires licensees to comply
with the DOT regulations in 49 CFR parts 170 through 189 relative to the transportation
of licensed material. Title 49 CFR 173.441(a) requires that each package of radioactive
material offered for transportation must be designed and prepared for shipment, so that
under conditions normally incident to transportation, the radiation level does not exceed 2
mSv/h (200 mrem/h) at any point on the external surface of the package, and the
transport index does not exceed 10. Contrary to this requirement, on August 31, 2006,
Entergy (Vermont Yankee) shipped a package containing radioactive material that was
not sufficiently designed or prepared to assure that, under conditions normally incident to
transportation, the radiation level on the external surface of the package would not
exceed 200 mrem/h. When received at the shipping destination on September 1, 2006,
the external surface of the package exhibited a radiation level of 820 mrem/h,
Following identification of this apparent violation, Entergy documented the condition and
completed a root cause review (CR-VTY-2006-02723); and instituted corrective
measures, including the suspension of radioactive material shipments that were
susceptible to discrete radioactive particle contamination until corrective actions could be
implemented. Subsequently, Entergy initiated various corrective actions including
measures to effect more extensive decontamination and survey of equipment prior to
shipment, application of plastic wrapping to contain and fix any remaining loose
radioactive material; application of shielding to susceptible portions of shipping
packages, and use of exclusive-use, closed transport vehicles. Pending determination of
a final safety significance, this finding is identified as an apparent violation, (AV)05000271/2006011-01, Radioactive Material Shipment Package Dose Rate Exceeded.
4OA6 Exit Meeting Summary
On October 6, 2006, the inspector presented the inspection results to
Messrs. Bill Maguire and John Dreyfuss and members of the VY staff. The
inspector asked whether any materials examined during the inspection should
be considered proprietary. No proprietary information was identified.
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Entergy Personnel
Duane Holmquist, Radwaste Radiation Protection technician
Mark VanDale, Radwaste Radiation Protection Supervisor
Kevin Pushee, Radiation Protection Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000271/2006011-01 AV Radioactive Material Shipment Package Dose Rate
Exceeded (Section 2PS2)
LIST OF DOCUMENTS REVIEWED
Condition Report CR-VTY-2006-02723 and associated Root Cause Analysis Report
EN-RW-102, Radioactive Shipping Procedure
FP-OP-012, Operation of the Advanced Crusher Shearer Procedure
LIST OF ACRONYMS
DOT Department of Transportation
LSA Low specific activity
SDP Significance determination process
Attachment