ML17054C186
| ML17054C186 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/15/1987 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17054C185 | List: |
| References | |
| 50-220-87-08, 50-220-87-8, NUDOCS 8706230503 | |
| Download: ML17054C186 (18) | |
See also: IR 05000220/1987008
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-220/87-08
Docket No.
50-220
License
No.
Priority
Category
C
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie Boulevard West
S racuse
13202
Facility Name:
Nine Mile Point - Unit
1
Inspection At:
Scribe
Inspection
Conducted;
Ma
26-27
1987
Inspectors:
H. J.
icehouse,
Radiation Specialist
Approved by:
H
W. J.
P
ciak, Chief
Effluents Radiation Protection
Section
ch~ s
date
date
Ins ection
Summar
Ins ection
on
Ma
26-27
1987
Re ort No. 50-220/87"08
A
surrounding
high radiation levels
on licensee's
Shipment
No.
1 WS-0697 noted at
the Brunswick Steam Electric Plant
on May 16,
1987
upon arrival of the
shipment.
Results:
Apparent violations of 10 CFR 71.5 including surface radiation levels
exceeding
49
CFR 173 .44(a) requirements
(Detail 4), failure to meet packaging
requirements
under
49
CFR 173.412
and 173.465 (Detail 5) and failure to include
Iron-55 activities in the shipping records
under
49
CFR 172.203(d)(i)
and
(d)(iii) and
49
CFR 172.204(a)(1)
(Detail 6).
8706230503
8706i 6
ADOCN, 05000220
8
!
0ETAILS
1.
Persons
Contacted
1. 1
Licensee
Personnel
- J. Blasiak, Chemistry Supervisor - Unit
1
- W. J. Connolly, guality Assurance
Program
Manager - Unit
1
- J.
N. Ouell, Chemistry Supervisor
- E ~
W. Leach,
Radiation Protection
Manager
- M. J.
Masuicca, Assistant to Operations
Superintendent
- T. J. Perkins,
General
Superintendent
- T. W.
Roman, Station Superintendent
N ~ Spagnoletti,
Manager,
Corporate Health Physics
"C. L. Stuart,
Superintendent,
Chemistry
& Radiation
Management
- P. Volza, Supervisor,
Radiation Protection
'
Other licensee
personnel
were also contacted
or interviewed during
the inspection.
1.2
NRC Personnel
- W. A. Cook, Senior Resident
Inspector
- C. S. Marschall,
Resident
Inspector
W. L. Schmidt,
Resident Inspector
"attended
the exit interview on May 27,
1987
2.
~Sco
e
On May 16,
1987,
a receipt inspection of two radioactive materials
shipping
packages
sent
by the licensee
to the Brunswick Steam Electric
Plant (Brunswick)
showed external
radiation levels of 1500 and
1800 millirem per hour (mrem/hr)
on contact
on the undersides
of the two
packages.
This special
reviewed the circumstances
associated
with those
packages
to determine
the apparent
causes
of the
radiation levels noted at Brunswick and compliance with NRC requirements
in 10 CFR Parts 20 and 71, U.S.
Oepartment of Transportation
(OOT) in
49
CFR Parts
170-189
and the licensee's
Technical Specifications.
Actions
taken
by the licensee
in response
to the violation noted during
NRC
Inspection
No. 50-220/86-15
were also reviewed.
Summar
of Events
On April 1,
1987, the licensee
received
a shipment
from the guad-Cities
Nuclear
Power Station (Cordova, Illinois) consisting of two packages
containing
a shearing
machine,
hydraulic equipment/hoses
to operate
the
shearing
machine
and
a support platform to be used in the operation of the
equipment.
This vendor-owned
equipment
was designed
to shear highly
radioactive stellite rollers
and pins from Boiling Water Reactor
(BWR)
Control
Rod Blades to allow subsequent
disposal
of the less radioactive
portions of the Control
Rod Blades
as low-level radioactive waste.
The
licensee
conducted
a receipt inspection of the two packages
under
licensee's
Procedure
No. S-RP-4,
"Picking Up, Receiving
And Opening
Packages
Containing Radioactive Materials," Revision
2 (October 4,
1985).
The receipt inspection
showed that the packages
were carried in a closed
trailer as
an "Exclusive Use" shipment.
No external
contamination
was
found
on the packages
and
a radiation survey of the truck and the packages
indicated the following:
Location
Radiation
Level
mrem/hr
Truck Cab
2 meters external
to
Trailer Truck
Contact Trailer
Contact
packages
<0.5
z5
~30
~110
The radioactive
shipping record
(RSR) accompanying
the shipment indicated
that the packages
contained
equipment contaminated with metal
oxides of
low-specific activity (LSA) with cobalt-60
as the only listed radio-
nuclide.
The licensee
accepted
the shipment
and the packages
were off-
loaded
and transported
to the licensee's
Unit-1 Refueling Floor.
The licensee
opened
the shipping packages,
assembled
the work platform,
lowered it into the fuel pool
and secured it to the fuel pool wall.
The
shearing
machine
and hydraulic equipment
were assembled,
tested for
operation
and
lowered into the fuel pool to rest
on the platform supported
by the overhead
crane.
On April 9,
1987,
the licensee
began cutting
BWR Control
Rod Blades which
had been
stored in the fuel pool since approximately
March
1986 following
their removal
from the Unit-1 reactor core.
The licensee
removed the
roller balls
and pins from fourteen
BWR Control
Rod Blades placing the
sheared
portions of the blades
in a storage
bucket
and returning the
Control
Rod Blades to a separate
in-pool storage
location.
The operations
were conducted
underwater
in the fuel pool
due to the high radiation
levels associated
with the operation.
The licensee
conducted
these
operations
under licensee's
Procedure
No. N1-FHP-31, "Control Blade Corner
Removal," Revision
2 (March 31,
1987).
A total of fifty-six "corners"
were sheared
and stored
in the fuel pool during the operation
from the
fourteen Control
Rod Blades.
On April 15,
1987,
the licensee
completed
the shearing
operation.
~
= '8k.g
~
Pt
~AW'g*'j"
g'hg,Q,())gal
~
~ I ~'Cj1 ~ 1'tJ)
On April 16,
1987,
the licensee
began
"hydrolasing,"
( i e
~ high pressure
water),
decontami nati on of the shearing
machine.
A survey of the shearing
machine
taken prior to initial decontamination
efforts
showed radiation
fields in excess
of 50 rads per hour on portions of the machine.
A sur vey
taken
on the machine following initial decontamination
showed reductions
in radiation levels to
12 and
25 rads per hour at the previously noted
greater
than
50 rads per hour locations.
From April 16,
1987 to April 28,
1987, efforts to decontaminate
the shearing
machine continued with
peri odi c radiation
surveys to measure
the reduction in radiation fields .
On April 28,
1987,
a survey prior to packaging
the shearing
machine
showed
two spots
reading
5 rads
per
hour
and
50 rads
per hour on the shearing
machine .
Other radi ati on levels were 'noted ranging
from 15 to 500 mi 1 1 i-
rads per hour.
Contamination
surveys
( "wipes" ) indicated
smearabl e
contamination
from 18, 000 di si ntegrati ons per minute
(dpm) to 350 mi 1 1 i-
rads per hour were still present
on the shearing
machine .
No additional
decontamination
of the shearing
machine
was done.
The shearing
machine
was wrapped with two lead blankets
and placed into
Shipping
Box No.
1 along with the hydraulic equipment
and hoses
~
Shipping
Box No.
1 was stored
on the Unit-1 Refuel
Fl oor.
On May 1,
1987,
the box
was surveyed
and
no radiation levels exceeding
140 mi 1 1 i rem per hour were
noted.
No external
contamination
on the box exterior was noted.
The platfor m was also "hydrol ased"
and,
on April 29,
1987, it was
removed
from the fuel pool, disassembled
and packed into Shipping
Box No. 2.
Shipping
Box No .
2 was essentially
a pallet with a rectangul ar cover to
enclose
the remaining five sides to make
a "box" .
The thirty-foot high
pl atform was dissembled
into three ten-foot sections with connectors
(f1 ange-bo
1t arrangements)
and packed .
During thi s operati on,
a contract
technician
(weari ng
a single set of cotton coveralls)
was found to be
contaminated with two "hot particles ~"
A "hot particle" was noted
on the
individual '
forearm and
a second "hot particle" was noted
on the thigh.
Skin dose calculations
made
by the licensee
assigned
dose equivalents
of
2,513
mi 1 1 irems to the right thigh and 2,010
mi 1 1 i rem to the
1 eft forearm
for
1 square
centimeter
areas
each at
a depth of 70 microns
~
A survey of the Control
Rod Blade Work
P 1 atform taken after decon tami na-
tion and immediately prior to packing
on Apri 1 29,
1987
showed radiation
levels from 5 mi 1 1 i rads per hour to
2 ~ 2 rads per hour and smearabl e
contamination
from 22,000
dpm to 1,300,000
dpm per
100 square
centimeters
~
The work platform components
were packed
and Shipping
Box No ~
2 was closed
and stored
on Unit-1 Refuel Floor.
On May 15,
1987,
the licensee
loaded the two packages
on an open
bed
trai 1 er and dispatched
them
as
1 i cen see
'
shipment
No .
1 WS-0697 to
Brunswick.
The vehicle was routed
as "Exclusive Use" by the licensee .
~ ~
S
~
~ I,
~
w.." .g,
>>
1,
<, ~,l'>>.
',~.
up~'
C g,'C'" t,"',; '
.."~ tOe'I I'rt~I ><V v~ J,,t,,+<
",p q'v
Y4
~
~
~ P.
At 1700
on May 16,
1987, radiation protection
personnel
at Brunswick
conducted radiation/contamination
surveys during that licensee's
receipt
inspection of Shipment
No.
1 MS-0697
and noted
1,500 millirems per hour
on contact with the bottom of Shipping
Box No.
1 (i.e. shearing
machine
and components)
and 1,800 millirems per hour on contact with the bottom
of Shipping
Box No. 2, (i.e. Control
Rod Blade Work Platform).
Initially, Brunswick personnel
were unable to reach
the licensee's
contact
and,
as
a result, notification to the licensee
was delayed until May 18,
1987.
The licensee's initial notification was received
from the equipment,
vendor
and subsequently
confirmed in
a telephone
conversation
with
Brunswick personnel.
The licensee
informed the
NRC resident
inspectors
on May 19,
1987
and they contacted
NRC Region I.
Based
on information
received in contacts with the Nine Mile Point and Brunswick
NRC resident
inspectors
and the licensee,
NRC Region I issued
PNO-I-87-44
on May 20,
1987.
On May 21,
1987,
the licensee's
Manager,
Corporate
Health Physics
observed
the opening of both shipping containers
on the Brunswick Refueling Floor.
"Chips" were
removed
from the inside bottom of Shipping
Box No.
2 which
read
24 rads per hour (combined
beta-gamma)
and
3 rads per hour
(gamma
only).
Visual examination of a "chip" showed it to be approximately 1/8
to 1/4 inch in--size.
On May 27,
1987, during the inspection,
a radiation control
foreman of
Brunswick reported to the licensee
that
a wipe of the inside surface of
Shipping
Box No.
1 showed
gamma readings of approximately
2 rads per hour.
"Chips", (i.e. object, visible to the eye) were not noted
on the wipe.
Gamma spectroscopic
examination
showed the radionuclides
to be
predominantly cobalt-60.
Packa
e Radiation
Levels
10 CFR 71.5 prohibits delivery of licensed material
to
a carrier for
transport
unless
the licensee
complies with applicable regulations
in
49
CFR Parts
1?0-189.
49
CFR 173.441(a)
requires that each
package of
radioactive materials offered for transport
be prepared for shipment
so
that under conditions normally incident to transportation,
the radiation
level
does
not exceed
200 mi llirem per hour at any point on the external
surface of the package.
Contrary to these
requirements,
on May 15,
1987,
the licensee
delivered
two packages
(as licensee
shipment
No.
1 MS-0697) to a carrier for
"exclusive use" transport to the Brunswick plant.
Ouring receipt
inspection
and radiation/contamination
surveys
made
by radiation
protection
personnel
at Brunswick, Shipping
Box No.
1 was
shown to have
an external
surface radiation level of 1,500 millirem per hour.
Shipping
Box No.
2 was
shown to have
an external
surface radiation level of
1,800 millirem per hour.
Since the packages
were transported
on
an
open
bed trailer, the applicable
package limit was
200 millirem per hour.
E
Examinations
by Brunswick personnel,
(for Shipping
Box No.
2 this
examination
was observed
by a licensee
representative)
noted "hot
particle" and "chip" contamination
in the packages
with radiation levels
consistent with those
observed
on the outside of the packages.
For the purposes
of this report, "hot particles" are defined
as
radioactive particulate
contamination
not readily observable
by unaided
eyes.
"Chips" are defined
as radioactive particulate
contamination
sufficiently large to be discernable
by unaided
eyes.
The licensee
apparently failed to prepare
the two packages
for shipment
iso.that conditions normally incident to movement
by truck would not cause
Ithe r'adiation levels to exceed
200 mi llirem per hour at any point on the
Iexternal
surface of the packages.
"Hot particles"
and "chips" were
apparently left on the contaminated
equipment
contained
in the packages
which could be
and were dislodged during shipment.
Supporting this
conclusion
are the following observations:
(1)
Surveys
made
by the licensee prior to the shipment did not note
any
radiation levels
on the surfaces
of the packages
exceeding
200 millirem per hour;
(2)
Surveys
made
by Brunswick radiation protection personnel
noted
localized radiation levels
on the package
surfaces
of 1500 and
1800 millirem per hour;
(3)
"Hot par;ticles" comparable
in radiation level to the radiation levels
on contact with the Shipping
Box No.
1 were noted during examination
at Bruniwick;
I
I
(4)
A "chip" comparable
in radiation level to the radiation levels
on
contact with Shipping
Box No.
2 was noted during examination at
Brunswick;
(5)
"Hot particles" dislodged during handling operations
on April 29,
1987 contaminated
the contract technician
on the forearm
and thigh;
and
(6)
The "hot particles"
and "chip" were found inside the boxes at
locations consistent with the contact
surface
readings
exceeding
regulatory limits.
Failure to prepare
the packages
in Shipment
No.
1 WS-0697 to ensure that
the radiation levels did not exceed
200 millirem per hour under the
conditions of truck transport constitutes
an apparent violation of
50-220/87-08"01
0
~
%
~
~Packa in
The licensee
repackaged
the shearing
and hydraulic machines,
hydraulic
hoses
and connections,
and the work platform components
in the two
shipping containers
in which that equipment
was received.
Neither
container
had been evaluated
to ensure that it met Type
A quantity
packaging
requirements
in 49
CFR 173.412
by test requirements
for Type A
packages
in 49
CFR 173.465.
The licensee
determined that the radioactive
materials
were
"Low Specific Activity" (LSA) under
49
CFR 173.403(n)(5).
The definition in 49
CFR 173.403(n)(5)
includes
the provision that the
radioactive material
not be readily dispersible.
The term, "readily
dispersible",
implies that the radioactive materials
cannot
be dislodged
in
a manner that increases
the radiological
hazards
associated
with the
package
in the conditions normally incident to its transport.
Implicit
in the concept of radiological
hazards
are exposures
by ingestion,
inhalation or other contamination
by the radioactive materials of an
individual and exposures
caused
by radiation fields resulting from
radioactive
decay of the materials.
Three observations
support
a conclusion that the radioactive materials
in
the two packages
of licensee
Shipment
No.
1 WS-0697 were readily
dispersible
and, thus, failed to meet the definition of LSA under
49
CFR
173.403(n)(5):
(1)
Routine handling of components
of the work platform by the contract
technician
on April 29,
1987 dislodged "hot particles"
subsequently
discovered
on that technician's
skin;
(2)
"Hot particles" were found inside Shipping
Box No.
1;
and
(3)
A "chip" was
found inside Shipping box No. 2.
As noted earlier,
observations
(2) and (3) are apparent
causes
of the
increased
radiation levels
on those
two packages
noted at Brunswick.
Observation
(1) provided
an indication approximately
two weeks prior to
shipment that radioactive materials
were dislodged
by handling
and
movement.
On April 29,
1987, three contract technicians
were
disassembling
and packing the components
of the Control
Rod Blade Work
Platform.
The technician closely involved in the operation
was found to
be contaminated
on the left arm and right thigh areas
by "hot particles"
at 1115.
The individuals were working under licensee's
Radiation
Work
Permit
(RWP) No. 87-3890-1 which covered the entire operation
from
April 1,
1987 through removal
from the Refuel
Floor for shipment.
Protective clothing requirements
on the
RWP failed to specify "wet suits",
(i.e. plastic or similar relatively impervious clothing).
Licensee's
Procedure
No. S-RP-S,
"Radiation
and Radioactive
Contamination Control,"
Revision
3 (September
30,
1986) in Table
2 recommends
a "wet suit" for
work conditions involving contamination
as
shown
on the licensee's
survey
of the Control
Rod Blade Work Platform (i.e. licensee's
Survey
No.
1 RB-10993) .
The technicians
were wearing single sets of cotton coveralls (with gloves,
shoe
and head coverings, etc.) during the work.
Radioactive particulate
contamination
was dislodged
from the work platform components,
came into
contact with technician's
skin in at least
two locations
and caused
unnecessary
beta
exposure
to the skin estimated at 2,513 millirems to the
right thigh and 2,010
mi llirem to the left forearm.
Under the licensee's
Radiological Incident Report (RIR) program,
the
licensee
reviewed the event,
estimated
the resulting beta skin exposure
and issued
a memorandum
to the radiation protection staff to require "wet
suits" for future similar'work activities
and conditions.
However,
the
licensee failed to recognize'hat
the material
was apparently dispersible
and, thus,
could be dislodged during movement in transport.
The inspector
noted that
had the disperjyble nature of the radioactive material
been
recognized,
the licensee
could have taken additional precautions
in
packaging it for shipment, 'such
as additional decontamination
efforts to
remove "hot particles"
and '"chips".
Since the radioactive materials
contained
in licensee
Shipment
No.
1 WS-0697 were "readily dispersible,"
the shipment failed to meet the
definition of LSA material
in 49
CFR 173.403(n)(5).
The radioactive
material did not meet the requirement for LSA material
and,
thus, it was
inappropriate
to ship the material
in packages
which had not been
shown to
meet Type A quantity packaging
requirements.
The estimated
316. 1 milli-
curies of cobalt-60 in the two packages
as: shipped
by the licensee
were
type A quantities
under
49
CFR 435 and normal
form under
49
CFR
173.403(5).
Failure to ensure that >the packages
in Shipment
No.
1 WS-0697
met Type
A quantity packaging
requidements
in 49
CFR 173.412
by tests
under
49
CFR 173.465 constitutes
an 'apparent violation of 10 CFR 71.5(a)(1)(i).
50-220/87-08-02
Iron-55
During
NRC Inspection
No. 50-220/86-15,
the licensee
was cited for failure
to identify the radionuclide Iron-55, its activity, and by that omission,
the total radioactivity associated
with several
radioactive waste
shipments.
Although Licensee's
Shipment
No.
1 WS-0697 did not involve
radioactive waste,
the licensee
was processing
BWR Control
Rod Blades
and
the radioactive contamination resulting
from that operation contributed to
the contamination
of the Control
Rod Blade Work Platform and shearing
equipment.
A vendor report of the radioactivity associated
with three
Control
Rod Blades
from the licensee's
fuel pool in 1985
showed the
presence
of Iron-55 at ratios of Iron-55 activity to Cobalt-60 activity of
0.64, 0.62
and 0. 14.
Iron-55 decays
by electron
capture with a physical
half-life of approximately 2.7 years.
Iron-55 is produced
by neutron
irradiation in the reactor
core of alloys in Control
Rod Blades.
Iron-55
cannot
be detected
by conventional
gamma spectroscopy
as conducted
by the
licensee.
Contamination
smears
of the shearing
equipment
and work
platform made
by the licensee
showed
100% of the
gamma activity resulted
from Cobalt-60.
Since the chemical
behavior of Iron and Cobalt are
similar, (i.e. transition metals),
the presence
of cobalt-60 in the
~
~
~
g ~,
)ran<
JWV% IW
4,
Vp, /
5 <<P4(
V
h
% 8+,g'1> P t
<<g )ti1
y
+:c. Q),
. ~
MA '%gal
Av, ~ 0
V)V<I
contamination
smears
indicate the possible
presence
of Iron-55 also.
Moreover,
radiochemical
measurements
made
by the vendor confirmed
Iron-55's presence
in similar
BWR Control Blades at the licensee's
facility.
Review of the licensee's
evaluation of the radionuclides
associated
with Shipment
No. ) WS-0697
showed that the licensee failed to
consider Iron-55's possible
presence
and to evaluate
the activity
contribution which that presence
would entail.
Such
an evaluation
was
reasonable
in view of the above.
The inspector
reasoned
that the arthimetric average
of the ratios of
Iron-55 to Cobalt-60 activities noted in the vendor's report
on similar
contamination
would provide
a rough estimate of ttfe potential
Iron-55
activity.
An arthimetric average ratio of 0.46 resulted.
Based
on the
licensee's
calculation of the cobalt-60 activity associated
with Shipment
No.
1 WS-0697 of 316. 1 mi llicuries,
use of the average ratio results in a
calculated
Iron-55 activity of an additional
145 millicuries.
In
addition, it is reasonable
to presume
the presence
of Iron-55 since the
BWR Control
Rod Blades
were
removed
from the licensee's
reactor
core
approximately
14 months before
shipment which is less
than
one physical
half-life for Iron-55.
Based
on guidance
issued
by the U.S. Department of
Transportation,
radionuclides constituting
more than
1% of the total
activity of the radioactive
shipments total activity must
be identified on
the shipping papers,
49
CFR 172.203(d)(i),
and
have their total radio-
activity included in the radioactivity of the shipment,
49
CFR 172.203
(d)( << i).
In addition,
the licensee certified that the radioactive material
in
shipment
1 WS-0697 was properly described
in the radioactive
shipping
record
when Iron-55 wasn't
named nor included in the total radioactivity
of the shipment contrary to requirements
in 49
CFR 172.204(a)(1).
Failure
to include Iron-55 and its associated
radioactivity constitutes
an
apparent violation of 10 CFR 71.5(a)(1)(vi).
50-220/87-08-03
Exit Interview
The inspector
met with the licensee's
representatives
(denoted
in
Detail
1) at the conclusion of the inspection
on May 27,
1987.
The
inspector
summarized
the
scope of the inspection
and findings as described
in this report.
The licensee's
representative
indicated that appropriate
corrective actions
would be taken following completion of the licensee's
investigation of the shipment.
At no time during this inspection
was written material
provided to the
licensee
by the inspector.
No information exempt
from disclosure
under
10 CFR 2.790 is discussed
in this report.
ftm+
0