ML17056A545
| ML17056A545 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/02/1990 |
| From: | Ronald Bellamy, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A544 | List: |
| References | |
| 50-220-89-80-EC, NUDOCS 9001160025 | |
| Download: ML17056A545 (40) | |
See also: IR 05000220/1989080
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
Docket no.
License
No.
50-220 89-80
50-220
Priority
Category
C
Licensee:
Nia ara
mohawk Power Cor oration
ann ie
oa
racuse
ew
or
13212
Facility Name:
Nine Nile Point
Unit
1
Meeting At:
NRC Re ion I
Kin of Prussia
Penns lvania
Meeting Conducted:
October 30
3989
Inspector:
.~
ascla
le
acl
1 les
a
1a
10n
P,otection Section, Facilities Radiation
Safety
and Safeguards
Branch
yC
Approved by:
~ iriVso
e
amy,
>e,
>>es
a ia
>on
a
e
Safety
and Safeguards
Branch
Meetin
Summar
Enforcement
Conference
at
NRC Region I, King of Prussia,
ennsy vanya,
on October 30,
1989, to discuss
the findings of NRC Inspection
Report
No. 50-220/89-80.
The topics discussed
related to your use,
since July
1981, of the Radwaste
Processing
Building sub-basement
as
a liquid waste
retention facility.
The meeting
was attended
by NRC and licensee
management
and lasted for
approximately
two hours.
900iih0025 900i02
- DOCK 05000220
DMIl
1.0 ~Pi i
t
DETAILS
1. 1
Nia ara
Mohawk Power Cor oration
NHPC
L. Burkhart, III, Executive Vice President,
Nuclear Operations
J. Willis, General
Superintendent,
Nuclear Generation
R. Abbott
Station Superintendent,
Unit 2
N. Spagno/etti,
Manager of Corporate Health Physics
C. Gerber,
Supervisor of Radwaste
Operations
G. Wilson, Senior Attorney,
NHPC
S. Wilczek, Jr.,
Manager Nuclear Technology,
NHPC
1.2
NRC Personnel
H. Knapp, Director, Division of Radiation Safety
& Safeguards
(DRSS)
J.
Greeves,
Acting Deputy Director,
DRSS
R. Bellamy, Chief, Facilities Radiation Safety
& Safeguards
Branch
W. Pasciak,
Chief, Facilities Radiation Protection Section
J. Wiggins, Chief, Division of Reactor
Projects,
Branch
No.
1
G. Heyer, Chief, Division of Reactor Projects,
Section
1B
W. Cook, Senior Resident
Inspector
NHP
1
& 2
K. Christopher,
Enforcement Specia)ist
2.0
~Por ose
The Enforcement
Conference
was held at the request of NRC Region I to
discuss
the apparent violations
and findings of an Augmented Inspection
Team (AIT) inspection
conducted
at Nine Mile Point Unit
1 on August 22-28,
1989.
The AIT inspection
was conducted to evaluate
the facts
and safety
implications associated
with your use,
since July 1981, of the Radwaste
Processing
Building sub-basement
as
a liquid waste retention facility.
The
discussions
at this meeting focused
on the identified apparent violations,
the root cause of the flooding event,
and the licensee corrective actions
to prevent recurrence.
3.0
Licensee
Presentation
The licensee
began their presentation
by stating that,
except for the
apparent violations,
the findings noted in NRC Inspection
Report
50-220/89-80
were essentially correct.
The licensee
stated that they had
additional
information which would clarify and address their concerns with
regard to the apparent violations.
The licensee
presented
the
NRC with
several
handouts
which are enclosed with this report.
The licensee
emphasized
that their position was that the flooding of the
sub-basement
was not safety significant,
and that the building was
used in
accordance
with its design.
The licensee did not agree with the
10
CFR
50.59 apparent violation because
they felt that the building was initially
designed to accommodate
the type of flooding that occurred
sn July,
1981.
The licensee
stated that no
ha6
been
done before the flooding.
The licensee
stated that they disagreed
with an apparent violation in the
area of 10 CFR 20.403.
Their position was that the flooding event
increased
contamination of the room, but not to the extent that
contamination
costs
were substantially
increased
over what they already
were.
They also presented
some examples
which they felt indicated
ambiguity in the requirements of this regulation.
They suggested
that
NRC
guidance
indicates that the regulation applies to costs
associated
with
equipment loss rather than costs to decontaminate.
They stated that the
room was not being
used
as
a drumming facility and that the equipment that
was in there at the time of the flooling was ultimately to be removed
and
discarded,
and
as
such there were
no fiscal losses
related to equipment
damaged
from the flooding.
The licensee
presented their cleanup plan.
This involved the acquisition
of a remotely operated
robot that would enter the room and handle the major
cleanup
and decontamination
tasks.
The robot was expected to star t being
used in early 1990.
The robot was expected
to save approximately
100
person-rems.
4.0
Concludin
Statement
NRC Region
I management
acknowledged that the cleanup actions
presented
appeared
to be responsive
to the HRC's concerns.
NRC Region I management
stated that the licensee
would be informed of the need for and the nature
of appropriate
enforcement
action relative to this incident at
a later
time.
EHFORCENEHT CONFERENCE
RELATING TO
HRC REGION
I
AUGMENTED INSPECTION TEAM (AIT)
INSPECTION (50-220/89-80)
OF THE
NINE NILE POINT UNIT 1
RADWASTE BUILDIHG
NIAGARA MOHAWK POWER CORPORATION
OCTOBER 30,
5989
AGENDA
RADNASTE EHFORCENENT
CONFERENCE
OPENING REMARKS
BACKGROUND AND CHINNOLOGY
DESCRIPTION
OF
EVENT
SAFETY SIGNIFICANCE
RESPONSE
TO NRC
CONCERNS
CLEANUP PLAN
SIINMARY
L. Burkhardt III
Executive Vice President
Nuclear Operations
J.
L. Hillis
General
Superintendent
Nuclear Generation
R.
B. Abbott
Hine Nile Point Unit 2
Station Superintendent
H. A. Spagnoletti
Nanager - Corporate Health
Physics
H. A. Spagnoletti
Manager - Corporate Health
Physics
C. A. Gerber
Nine Nile Point Unit 1
Supervisor
Radwaste Operations
J.
L, Hillis
General
Superintendent
Nuclear Generation
By pass
Take up
Switch cogectin
Floor plan
shows
route
taken
by
drum when it cn-
tcrr cncloscd <<or.
age
area.
Truck
will take
it from
cast clcvator to fll-
llng stanon.
Then
fOlcd
drum
will
move
lo
storage
room
on
onc
of
lhrcc separate
lcv-
cis.
IVcst
clcva-
tor
will toke
lt
to any Icvyj.
East
litt
Filling
stations
nsole
~ Copping unit
West
litt
Switch
distributIng
42
MAtERIAL HAHOLIHG EHGIHEERIHG
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" ..The".ayatear compr5fea. an extrefnely
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.'coraplex netvvork of overhead'.traddng
"-'ctivedobrfs-ahalqdouacarigohandfed"-.:
c'omponents, custom canter units, dmtor
vftftoutrisfc by one'matr at'a console.. ', drives, sensing and moaitorfng
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Designed to vvorfc for decades 'shout
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ration a Nine Mffe poi,t.
maf toaance, the remotely cont
fled
Nuclear Statioa at Oavvego, N.Y. De-
p',pe~~~"~ n'
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signed to meet tho criticalspecifications
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tod b
th
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dfb
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df ~ment for dfsposaf of radioactive wastes
~e
the e.tem ~ ~~ ~ m'.
ia comPlete ~sty.
stalled by the Automated Handling Sys-
~ The oatiro oporatfon fs controlled from a
toms DivisionofEatoa Yale S Tome fnc.
remote console outside protective con.
I
m atomic yarner yiaat
crete Kaffs. The specfaBy modfffed
haadlfag system itself fa protected by
faferfccfca anangod
on a logic basfs'-
no action can tahe place until predator.
mined conditions are met.
This single-source, complete turnfcoy
system dramatfcalfy illustrates our en-
gineering capabilities.
Write us for the free illustrated bro.
churo. "Turnkey Systems
for Moving
Materials"t Automatocf Handling Sys-
tems Division. 1815 Connecticut
Ave-
nue. N.W., Washington. D.C. 20009.
~ ATONI AUTOMATEDHANDLINGSYSTEMS DIVISION
hlATERIALSHANDLINGGROUP
<',e
if'
~
t
r p
~ 1
(
plants;nat
are
ur:ven
ny ~tomic
energy.
These
tuels
re like no othe.
matenais
used
in other energy conver.
uon
systems.
F:rst ut all. the:
are .adioacnve
so thev
, must
be
nandleci
remote!y.
This
means
not
only
the
- uei
itseit. but
iso
tne debris
that accumulates
in the
- eac;or
water.
The
water
circuiates
througn
a
closed
'.oop:ircuit und is;urned
to steam.
Then it is
.fed into
ihe turbines
which turn
a generator
at the
end of the
main shatt.
It is this
huge
generator
that
provides
an
electncal
transmission
gnd with 345.000
voits ot'ower.
The water.
once ii is deployed
as
steam
in the tur-
bine.
is cooled
and
returned
to
a
series
ot
nlters
and
c!eanup
demineralizers.
The matenal
tiltered out even-
tually precipitates
into a solid
waste.
This includes
the
resins that are involved in ion exchanges
in the demineral-
izers.
The contaminated
material
is accumulated
in an
enclosed
storage
area under the reactor. When enough
is
on nand. it is mixed with cement.
dumped into 55-<talion
drums.
and stored
in isohted
chambers
where
a decay-
ing action
takes
phce.
The decay
time depends
on
the
half-life or'he
radio
nuceli that
are involved. When
a
reasonably
safe
level is reached.
the barrels
are removed
and buried in a dump some mites away. The ume period
could be anywhere
from l0 days
to two years.
Removal of the radioactive debris
at Niagara 3lonawk
Corporation's
<<line-Mile Point
Power Phnt
at
Oswego.
V. Y..
is
done
with
a
specially
modified
Astroveyor
system
created
by
Automated
Handling
Systems.
Inc.
a
subsidiary
of
Eaton
Yale
4,
Towne.
Despite
the
straightforwardness
of
the
overall
concept.
the
entire
system
with
its
remote
controls
and
carriers
is
very
complex.
But most imponant
is that the enrire installa-
tion
is
enclosed
in
three foot-thick
walls.
One
man
standing
at a console behind a concrete wall controls the
operauon.
i
7
~ 11 attr mate r a 'roitt 'h r rractr) ~ is rpiixcd
'<'.'th era<rift
und.
at
command.
pnurs
<to<en
into
one
of
two filling
stations.
Then
the drum
<rill be
ordered
to ntove
to
the
capp<lip tt<itl<iit,
~ .
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~
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rt
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Fail-safe
reqviremen]s.
-Once
the conveyor
system
is installed.
there
must
be
no routine maintenance
re-
quired
within
the
enclosure."
That
is
the
statement
foui.d in:he Atomic Ence~
ommission
specifications
handed
to Automated Handling Systems
<<ngineers.
The
power
people
had
to
be
sure
that
once
the
system
started
up. there
woWd be
no breakdown.
i<or should
a man have to enter
the deadly interior ot'he
storage
area
to make
adjustments.
Therefore,
the sys'em
is de-
signed
to work for decades.
rather than years.
It meets
all specifications
of the Atomic Energy
Commission.
It Is difficult to
picture
an
installation
that
would
fulfill these
requirements,
It is also equally ditficult to
picture the remoteness
of the conveyor components
once
they are operating
behind
the concrete
wa<.'s.
They are
so
near.
yet so far.
Thev might as well be in Ahska
when it comes
to routine maintenance.
Sanding
repair
men
into
the
insta!htion
would
require
the
~earing
of
protective
clothing,
removing
drums
curremly
in
I:crage.;vashing
down
the
ent."re
area
with high pres-
sure
hoses,
and
taking readings
to see if any
residual
radioacuvity were
present.
The
operation
within the
enclosure
is intriguing to
say the least.
Everything that moves
is controlled from
the
remote
console
outs!de
the
thick
protective
con-
crete wal!s. The operator
is never exposed
to any radio-
activity. either direct or retlected.
All storage
is within
four
levels
beneath
the
surface.
Any
stray
emission
is impossible.
D"<<<ns rrina>>i ttn,'hrir cr:rr<rr dtinn: vora.r prriud in r>>nms
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(i<ii iinr. ii liril
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timr>>i
radi>>active
<1 ~ '.<tc h<at hrra
r< acli<'d, rh<<'riaii <s <<'t iau r>> a li>a<line urru.
Storing procedure.
Starting oif. the empty drums are
placed
ori
an
elevator
at
the
storage
level
which
is
located
just abo~e
the
second
level filling station.
This
AMg<<<l. tilde
di
UHIT COMMERCIAL
BACKGROUND AND CHRONOLOGY
NINE NILE POIHT UNIT 1
RADWASTE 225
ELEVATION
CONTAMINATION OVERVIEW
DECENBER 1969
STOPPED
USING WASTE PILLING STATION 225
SPILL OCCURRED
RADWASTE BUILDING EL, 229 and EL. 225
CLEANUP AND DECOR
STARTED
INITIALCLEANUP AND DECON STOPPED
DUE TO
HIGH EXPOSURE
RISKS TO STATION PERSONNEL
RECIRCULATION SYSTEM PIPING REPLACEMENT
ADDITIONAL SURVEYS ELEVATIOH 225
NEW RADWASTE BUILDING IN SERVICE
RADWASTE TANK AND PIPiNG MODIFICATIONS
DESIGN STUDIES
HMPC RESEARCH
AND DEVELOPNENT DEPARTMENT
ASSISTANCE REOUESTED
1978
JULY 1981
JULY 1981
OCTOBER 1981
MARCH 1982-JUNE
1983
DECENBER 1983
1983-19Iti
BACKGROUND AHD CHRONOLOGY (CONT'Dj
ADDITIONAL SURVEYS ELEVATIOH 225
RADWASTE TANK AND PIPING NODIFICATIOHS
JULY 1985
1985-1987
ROBOT USED TO PERFORN
SURVEY OF ELEVATION 225
SUNNER 1986
R & D SERVICES
REQUESTED
FOR CLEANUP
PLAN/BUDGET SUBNITTED TO PSC
NARCH 1987
1987
REQUEST
FOR QUOTES
FOR ROBOTICS EQUIPNENT WRITTEN
NARCH 1988
IHPO EVALUATION CONCURRING CLEANUP PLANS
CONTRACT WRITTEN REDZOHE ROBOTICS
FOR
BUILDING OF ROBOT
NEDIA INTEREST
AUGNENTED INSPECTION TEAN INSPECTION
DELIVERY OF
ROBOT AHD START CLEANUP
OF ELEVATION 225
CONPLETE CLEANUP RADWASTE 225
NARCH 1989
JULY 1989
AUGUST 20,
1989
AUGUST 21,
1989
DECEHBER 1989
OVERVIEW
CAMERAANDLIGHTS
DRIVENCARRIFR
GRIPPER
.
CAMERAANDLIGHTS
..
IIYOnnUI.IC
POWER SUPPLY
-L
ELECTRONICS
ENCLOSURE
SLAVE
MANIPUALTOR
STIFFLEG
TETIRER
MANAGEMENTSYSTEM
DESCRIPTION OF
EVENT
PROBLEMS
ENCOUNTERED
4
MAINTENANCE OF CATION TANK LATERALS
REACTOR BUILDING CLOSED
LOOP COOLING OUT OF SERVICE
4
IMPACTED WASTE EVAPORATOR OPERATION
POOR
EVAPORATOR PERFORMANCE
PIPE
LEAK
4
CROSS
CONTAMINATION OF
LOW CONDUCTIVITY STREAM
4
HIGH INVENTORY OF SLUDGE/HIGH CONDUCTIVITY WATER
OPTIONS/ACTIONS COHSIDERED
ZERO DISCHARGE TO LAKE ONTARIO PHILOSOPHY
SUSPEND/DELAY UNIT STARTUP
PROCESS
INVENTORY WITH EXTERNAL SYSTEMS
RADWASTE BUILDING ELEVATIOH 225'ONSIDERATIONS
DESIGNED TO HOLD WATER/SLUDGE
NEAHS AVAILABLETO PROCESS/RECOVER
WATER THROUGH
RADWASTE SYSTEN
SAFETY SIGNIFICANCE
DESIGN OF RADWASTE BUILDING SUB-BASENEHT AREA
EVALUATION OF SUB-BASENENT AREA
PAST PRACTICE
USE
OF SUB-BASENEHT AREA
REASON
FOR
LEAVING LIQUID ON RAOWASTE ELEVATIOH 225'
'
'ESIGN
OF RADWASTE BUILDING SUB-BASENENT AREA
DESIGN CONTROL FOR SPILLED LIQUIDS IS TO ALLOW FLUID TO SEEK
LOWER LEVEL
DESIGN BASIS OBJECTIVE IS TO RETAIH RADIOACTIVE WASTE IF
THEY ACCIDENTALLY LEAK FROW THE SYSTENS
DESIGNED TO RESIST HYDROSTATIC PRESSURE
AND UPLIFT DUE TO
EXTERNAL FLOODING
DESIGNED TO HANDLE ESSENTIALLY UNLINITED LIVE LOADS ON FLOOR
4
DESIGNED AS A CLASS
I
STRUCTURE
REINFORCED
CONCRETE WALLS PROVIDE ISOLATION AND RADIATION
SHIELDIHG
PRESENCE
OF WATERSTOPS
IN BUILDING'S CONSTRUCTION JOINTS
4
FLOORS
AND WALLS HAVE EPOXY COATINGS
4
FLOOR COVERED WITH 1
TO 2
INCHES OF HIGH STRENGTH
FLOOR
TOPPING
4
AIR SUPPLY TO
LOW COHTANINATIOH AREA, EXHAUST DUCTS LOCATED
IH HIGH AIRBORNE POTENTIAL AREA
PERINETER DRAINAGE SYSTEN COLLECTS NOUND WATER
'
'VALUATIONOF SUB-BASENEHT AREA
COHFIRHED
HO RISK TO THE HEALTH AND SAFETY OF SITE WORKERS
AND
PUBLIC
BASED
OH BUILDING FEATURES PREVIOUSLY DESCRIBED
HO
INDICATION OF
LEAKAGE OUTSIDE SUB-BASENEHT AREA
CONCLUSION CONSISTENT WITH NRC AIT CONCLUSIONS
'
'AST PRACTICE USE
OF SUB-BASEMENT AREA
WATER ACCUMULATIOH ON FLOOR DURING 19TO's
NOT A SAFETY PROBLEM
CONSISTENT WITH DESIGN
WATER RETENTION TO MINIMIZE DISCHARGES TO LAKE
'
'EASN
FOR LEAVING LIQUID ON 225'
REDUCE POSSIBILITY OF AIRBORNE CONTANINATION
REDUCE WORKER EXPOSURE
IN AREA
RESPONSE
TO NRC CONCERNS
IN INSPECTION
REPORT 50-220/89-80
FAILURE TO NOTIFY THE NRC IN ACCORDANCE WITH THE REPORTING
REQUIRENEHTS
10
CFR 20.403
NOTIFICATIONS OF
INCIDENTS
a)
INNEDIATE NOTIFICATION.
Each licensee shall
immediately report
any events
involving byproduct,
source,
or special
nuclear
material
possessed
by the licensee
that
may have caused or
threatens
to cause:
(4) Damage to property
in excess
of S200,000.
b)
TWENTY-FOUR HOUR NOTIFICATION.
Each licensee shall within 24
hours of discovery of the event,
report any event involving
licensed material
possessed
by the licensee that
may have caused
or threatens
to cause:
(4) Damage to property in excess of S2,000.
RESPONSE'.
IT IS NIAGARA MOHAWK'S POSITION THAT NOTIFICATION OF THE NRC WAS NOT
REQUIRED UNDER TOCFR20.403.
DAMAGE FROM THE SPILL WAS NEGLIGIBLE.
THE
SUB-BASEMENT AREA WAS DESIGNED TO STORE
AND HANDLE RADIOACTIVE MATERIAL
AHD BE SUBJECT
TO PERIODIC CONTAMINATION AHD DECONTAMINATION AS REQUIRED,
ALSO,
THE CLEANUP/DECONTAMIHATIOHCOSTS
ARE NOT MATERIALLYAFFECTED BY
JUSTIFICATIW
ACTUAL PROPERTY
DAMAGE LESS
THAN $2,N ,
THE SUB-BASEMEHT AREA WAS DESIGNED
FOR PERIODIC CONTANINATION AND
DECONTAMINATION
VIEW CONSISTENT WITH IHDUSTRY PRACTICES
SPILL HAD MINOR EFFECT
ON CLEANUP PLANS
DRUNS UNACCEPTABLE FOR BURIAL
STNED
FOR
FUTURE PRXESSIHG
PRXESSING
TECHNIQUE BEING EVALUATED
PART 2O STATEMEHTS OF COHSIDERATIOH (JULY 29) 1983)
EVACUATIOH OF
ROOMS
OR BIIILDINGS"