ML070640329

Consumers Energy Co Letter to EPA R5 Re Inadvertent Torch Cut of Containment Shell Piece at Big Rock Point

ML070640329
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/10/2005
From:	Haas K Consumers Energy
To:	Martig T NRC/FSME, Environmental Protection Agency
References
Download: ML070640329 (5)

Text

ConsumersEnergy A CMS Energy Company Big Rock Point Restoration Project Kurt AL Haas.

10269 US-31 North General Manager Charlevoix, MI 49720 November 10, 2005 Mr. Tony Martig U.S. Environmental Protection Agency, Region 5 Toxics Program Section 77 W. Jackson Blvd. (DT-8J)

Chicago, IL 60604 Re: Consumers Energy Company - Big Rock Point Containment Shell Dismantlement -

Notification of Inadvertent Torch Cut of Containment Shell Piece

Dear Mr. Martig,

Consumers Energy Company is providing notification of a deviation in the provisions contained in the March 21, 2005, letter granting TSCA approval under 40 CFR 761.62(c) for dismantlement of the Containment shell. This notification is made in accordance with Conditions of Approval (General Item 3) contained in the March 21, 2005, letter.

On November 9, 2005, at approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, a contract laborer inadvertently torch cut a containment shell piece without prior removal of paint along the exterior cut line. The containment piece originated from the equipment lock and was partially coated with silver-colored paint known to contain PCBs above the 50 ppm limit. The containment subsections have been labeled and placed in the designated location for containment sections coated with paint above the 50 ppm PCB limit. A condition report, C-BRP-05-0234, was generated immediately to document this occurrence and address corrective actions to prevent recurrence; a copy of this condition report is attached.

Please contact Tracy Goble (231-547-8389) should you have any questions regarding this notification.

Sincerely, Kurt M. Haas Site General Manager Big Rock Point Restoration Project cc: KE Pallagi, Big Rock Point TA Goble, Big Rock Point WJ Wilson, Consumers Energy JP Dickey, Consumers Energy Amy Merri cle,-MichiganDepartment of Environmental Quality US-NRC NMSS Project Manager--

USNR- Region 1-1 Decommissib-ing Inspector - Big Rock Point

TITLE PCB Painted Sphere Pieces Inadvertently Torch Cut Discovery Date and Time 11/9/05 - 1500 Date of Occurrence if different from Discovery Date Job/System EVENT INFORMATION (IF APPROPRIATE ATTACH ADDITIONAL SHEETS/NOTES/STATEMENTS, ETC.)

DESCRIPTION OF INCIDENT OR ISSUE: (WHAT OCCURRED OR WHAT IS THE ISSUE) -

While sizing pieces 75 & 76 of the sphere, a worker inadvertently torch cut through PCB painted material. The previous day, another crew had marked and scabbled cut lines for both segregating the PCB areas and sizing the PCB pieces on one side of the pieces. The crew intended to segregate the PCB material and move the two pieces to the north lay down area orior to sizina. Some of the cut lines were marked "Do Not Cut" and desianated the area that contained PCB paint naint on on orior toofsizing.

a aoutside of the SomeThe cut lines were marked "Do Not Cut" and designated the area that contained PCB the the piece. areas within the lines marked "Do Not Cut" included other cut lines for sizing that were not marked.

The followina day, completion of the work was assianed to a different crew. There was no turnover between the two day completion of the work was assigned to a different crew. There was no turnover between the two crews. flowina The The worker was instructed to cut all lines not marked "Do Not Cut". The position of the pieces was such that worker could not see that some of lines he was cuttina traversed the areas of PCB paint on the underside of the Dieces.

APPARENT CAUSE:

INITIATOR The work group assigned to perform a iob was changed prior to completion. The turnover and communication of the status of the work was inadeauate.

IMMEDIATE ACTION(S) TAKEN: Sr-ap=, ,.=o,* PCB p,, ,, 1o4,#-,,,

4 "*PS I5 ,q , t..1 WORK ORDER/REQUEST/INSTRUCTION NUMBER USED TO CORRECT CONDITION:

RECOMMENDATION(S) (Operability and/or Corrective Action)

REFERENCES / 7 /

Initi~tAr kv~vin flv~rlv Date 11/10/05 TimeA 1100*

Intao Kev..in Ovri .. - Date-----"-~.-.j 11100 Time 110 v

BRP156 08/05/05 Page 1 of 3

TS Operability applicable? El Yes 2ý No Equipment Identified? El Yes t" No SGM(or If YES, equipment operable? El Yes El No Method designate): If NO, equipment functional? El Yes El No f9 N/A Immediately Reportable: El Yes J& No Reportable to NRC? El Yes El No Nonconforming Material? El Yes N No SGM (or El Part 50 COti-C,'-,.-e El Part 72 10CFR21 Evaluation? El Yes P No designate): 1 Hr 4 Hr 24 Hr 8Hr 60d Other El El El El E SGM (or designate): Date _-_0_o__"

Significance Level: El 1 El 2 El 3 El 4 Radiological Incident? El Yes El No Industrial Safety? El Yes El No Comments:

Review/

Approval Assigned to: Due Date:

Comments:

SGM (or designate): Date:

EVALUATOR Evaluator: Date: CE Supervisor: Date:

CLOSEOUT SGM (or designate): Date:

BRP156 08/05/05 Page 2 of 3

INSTRUCTIONS FOR COMPLETING CONDITION REPORT INFORMATION PURPOSE COMPLETED BY Title Provide a short description for use in computerized reports, time identified and date. Initiator Description of Provide a clear description of the issue. Provide specific details of the occurrence such Initiator Occurrence or *as equipment number, status of the plant or system, and/or copies of relevant Condition documents. If able, answer these questions: what occurred or what is the issue, who was involved, when did it occur, where did it occur, how did it occur. Attach pictures, drawings or sketches.

Immediate Actions Provide details of immediate actions taken to address the issue. Initiator Taken Recommendations Provide recommendations that may correct the issue or prevent the issue from Initiator recurring.

References Provide references that apply to the issue and, if a Work Request is generated, write Initiator the Work Request Number here.

Operability Determine if the immediate actions taken were appropriate. If no immediate actions SGM (or were taken, determine if any are needed. designate)

Reportability Determine reportability requirements. Determine nonconforming material status and if SGM (or 10CFR21 Evaluation is necessary. designate)

Review/Approval Determine significance level of the CR, determine if the issue is a Radiological Incident, SGM (or determine due date, assign an evaluator or team, review if the issue is a recurring designate) problem, and review for tampering and/or sabotage and notify Security if appropriate, sign and enter the CR in the Corrective Action Logbook.

Evaluator Evaluates the Condition Report issue per the guidance provided in the CA Handbook. Evaluator Reviews and approves completed actions. Supervisor Closeout Review Ensures corrective actions are completed, completes Closeout Administrative Review SGM (or and updates the Corrective Action Log Book. designate)

BRP156 08/05/05 Page 3 of 3

C- &P-405-o 03~L31Y Containment Shell Sizing Process Control Improvements 11/10/2005 As a result of the inadvertent torch cutting of the silver PCB paint, the following actions will be incorporated:

No work will begin on ring 2 until all sections that contain PCB paint have been identified by their number. Once identified, the cut lines will be clearly marked for these sections on the exterior of the shell section and labeled 'PCB'. Each section that contains PCB material will have a drawing made up with dimensions outlining the location of the PCB material.

Once this is completed, the work on ring 2 can restart.

Prior to cutting out a section that contains PCBs, the following people will be notified:

An Environmental rep., Kevin Overly, PMC rep. and Stu Powrie. These people will give approval for section to be removed. This will be documented on the drawing sheet for that particular section.

Kevin Overly will oversee the removal activity.

These sections will be placed in the North end PCB area for separating out the PCB radwaste material.

The drawings will be used to mark the cut lines on the interior side of each section. The interior side will be clearly marked as to the PCB areas. If torch cutting will be utilized, scabbling of the interior coatings will be performed at this time. Stu will be responsible for this activity.

The section will be turned over and set so the exterior is facing up. During this process, Kevin Overly will ensure the cut lines match up.

Prior to cutting, a brief will be performed with Env. Rep, Kevin Overly, Stu Powrie, PMC rep., and Safety. This will be documented by signing the drawing page for that particular piece. Upon the above peoples' concurrence, the cutting process can begin from the exterior side.

Kevin Overly will be present during the cutting process to ensure lines are followed.

Once cutting is complete, pieces will be dispositioned in accordance with the plan.

Prior to work commencing on Ring I the same activities will be performed.