ML18066A307
| ML18066A307 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/01/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18066A308 | List: |
| References | |
| 50-255-98-18, EA-98-443, NUDOCS 9810060168 | |
| Download: ML18066A307 (10) | |
See also: IR 05000255/1998018
Text
U.S. NUCLEAR REGULATORY COMMISSION
Docket No:
License No:
Report No:
Licensee:
Facility:
.Location:
Dates:
Inspector:
Approved by:
9810060171 981001
POR
AOOCK 05000255
G
REGION 111
50-255
50-255/98018(DRS)
Consumers Energy Company
Palisades Nuclear Generating Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
August 24 - September 2, 1998
R. L. Glinski, Radiation Specialist
Gary L. Shear; Chief, Plant Support Branch 2
Division of Reactor Safety
EXECUTIVE SUMMARY
Palisades Nuclear Generating Plant
NRC Inspection Report 50-255/98018
The purpose of this inspection was to review a transportation incident in which a Class 7
(radioactive) package, that was shipped as an exclusive use shipment on an open transport
vehicle, exceeded the NRC and Department of Transportation (DOT) limits for radiation levels
on the external surface of the package. In addition, this review covered the implemer:itation of
transportation procedures, the preparation of shipping papers, and the performance of radiation
surveys conducted in support of this shipment. The following conclusions were reached:
An apparent violation was identified concerning the failure to transport a package of
radioactive material in accordance with 49 CFR 173.441, i.e.~ radiation levels on the
external surface of the package exceeded the stated regulatory limits. However, due to
indications that inherent problems with the cask may have been the cause for the
violation, the actual root cause of the violation could not be determined at the time of the
inspection. (Section R1 .1)
The shipping papers for the radioactive material shipment were prepared in accordance
with regulations, plant procedures and expectations. However, several aspects
regarding both survey and documentation practices for the shipment did not meet either
procedural requirements or management expectations, and the lack of normally
available personnel resources contributed to these deficiencies. (Section R4.1 ).
2
Report Details
IV. Plant Support
R1
Status of Radiological Protection and Chemistry (RP&C) Controls
R1 .1
Radiological Controls for the Loading and Preparation of a Shipping Cask
a.
Inspection Scope (IP 86750)
The inspector reviewed the radiation work permit (RWP), radiological surveys, and
dosimetry data for the loading and temporary storage of a Type A shipping cask. The
inspector also interviewed plant personnel regarding the controls implemented during
this evolution, and the inspector interviewed plant and vendor personnel regarding the
radiation levels detected by the engineering vendor at their site upon receipt of the
package.
b.
Observations and Findings
On August 12, 1998, plant personnel removed a highly irradiated reactor surveillance
- capsule from the spent fuel pool (SFP) and placed it into a Type A shipping cask. The
capsule had been previously placed into a specially designed holding basket and had
been allowed to decay for 114 days in the SFP. This particular task involved transferring
the capsule/basket from the SFP to the shipping cask, as the cask was suspended over
the SFP. The licensee ~ad contracted to transport this surveillance capsule to an*
engineering vendor for metallurgical analyses, and an experienced vendor
representative was onsite to aid in the proper loading of the cask.
A previous assessment by the vendor (based on the chemical composition of the
capsule, the neutron irradiation from its accelerated position in the vessel, and a 60-day
decay period) had estimated a maximum dose rate of approximately 106 millirem per
hour (mrem/h) at the centerline of the loaded cask. The initial surveys of the loaded cask
on the refuel floor detected a ma.xi mum dose rate of 110 mrem/h on contact. Based on
dose rates that were consistent with the vendor's estimation and the assistance of the
contractor, licensee staff concluded that the capsule/basket assembly had been correctly
loaded into the cask. The end plates were bolted onto the loaded cask, which was then
transferred to the shipping bay and secured onto the dedicated flatbed trailer. During
this evolution, the licensee expended 45 mrem whole body dose and less than 20 mrem
extremity dose, which were reasonable for the work accomplished.
Radiation surveys of the cask and trailer bed, which were performed to determine the
appropriate radiological postings for the area, were consistent with the initial surveys on
therefuel*floor. On August, 14, 1998, the radioactive materials shipping supervisor
(RMSS) and a heal.th physi.cs. te.chnician. (He.I)-conducted a.more extensive survey of
the cask and truck/trailer in preparation for shipment. The dose rates at the truck cab
and at 2 meters from the lateral surfaces of the vehicle were within the regulatory limits
and were also consistent with the estimates provided by the engineering vendor.
3
However, the RMSS detected a single area on the bottom of the cask surface with a
radiation level of 170 mrem/h, which was verified by the HPT.
On August 17, 1998, the RMSS reviewed the shipping papers with the carrier, reviewed
the shipment surveys, and examined the material condition and placarding of the trailer.
After reviewing the instructions for this exclusive use shipment with the carrier, the
RMSS allowed the shipment to leave the site. This shipping cask (Serial No. TTC-5)
was an authorized Department of Transportation (DOT) Specification 7 A Type A cask.
On August 18, 1998, the carrier delivered the shipment to the vendor's sub-contractor
facility, as this sub-contractor was to conduct the metallurgical analysis of the
surveillance capsule. However, the shipping papers specified that the engineering
vendor was to receive the shipment. In addition, the sub-contractor surveyed the cask
and found a discrete area on the external surface of the package with a radiation level
of 300 mrem/h, which was in excess of the regulatory limit of 200 mrem/h for an *
exclusive use shipment on an open transport vehicle. The sub-contractor contacted the
NRC in accordance with 10 CFR 20.1906(d)(2), and then contacted the licensee.
The licensee immediately dispatched the RMSS and the site health physicist to the
sub-contractor's site to examine the cask and conduct a confirmatory survey. Prior to
reviewing the sub-contractor's data, the RMSS conducted a survey and identified an
area of approximately 10 centimeters (cm) in diameter'having radiation levels of 280-
380 mrem/h, which was consistent with the sub-contractor's measurements. This area
- was approximately 0.75 meters from the 170 mrem/h area that was identified at the
licensee's facility. The RMSS also found the 170 mrem/h area and indicated that it
appeared to have moved several cm axially along the bottom of the cask .
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, comply with the applicable
requirements of the regulations appropriate to the mode of transport of the Department
of Transportation in 49 CFR Parts 170 through 189. 49 CFR 173.475(i) requires, in
part, that before each shipment of any Class 7 (radioactive) materials package, the
offerer must insure by examination or appropriate tests that the external radiation levels
are within the allowable limits in 49 CFR Parts 171-178. 49 CFR 173.441(a) requires, in
part, with exceptions not applicable here, that each package of radioactive materials
offered for transportation be designed and prepared for shipment, so that under
conditions normally incident to transportation the radiation level does not exceed 2
millisieverts per hour (mSv/h) (200 mrem/h) at any point on the external surface of the
package.
The existence of external surface radiation levels in excess of the applicable regulations
is an apparent violation of NRC and DOT requirements (EEi 50-255/98018-01).
However, interviews with the licensee, the engineering vendor, and with another nuclear
facility, indicated that there may be an inherent problem With the design and/or
manufacture of the cask, which could have been the root cause or a contributing cause
of the violation. During the removal of the basket/capsule assembly from the cask,
4
J
various personnel observed that very slight movements of the basket/capsule resulted in
significant fluctuations of the radiation levels on the surface of the cask, from 280
mrem/h to 190 mrem/h. In addition, another nuclear facility which had used this cask for
the same purpose in 1997 stated that their surveys detected two discrete areas on the
cask where there appeared to be streaming of radiation through possible voids in the
cask shielding. Finally, the engineering vendor stated that, based on the design of the
basket, basket holder, and cask, there was a potential for the basket/capsule assembly
to move up to 5 cm in the cask. Since the cask was mounted on the truck bed at
approximately a 10 degree angle, the inspector concluded that the basket could have
moved during transport, which would be due to cask design, and that the movement
could have contributed to the increased contact dose rates.
Based on the information stated above, the actual root cause of the violation (either
inadequate survey/preparation of the shipment or inadequate design/manufacture of the
cask) could not be determined at the time of the inspection. However, the licensee and
it's vendor were evaluating the cask and this incident to determine the root cause.
c.
Conclusions
An apparent violation was identified concerning the failure to transport a package of
radioactive material in accordance with 49 CFR 173.441, as the radiation levels on the
external surface of the package exceeded the stated regulatory limits. However, due to
indications that inherent problems with the cask may have been the cause for the
violation, the actual root cause of the violation could not be determined at the time of the
inspection ..
R4
Staff Knowledge and Performance in RP&C
R4.1
Poor Performance in Implementing the Shipping Procedure for Shipment 98-067
a. *
Inspection Scope CIP 86750)
b.
The inspector reviewed the applicable procedure (Procedure No. HP 6.20, "Radioactive
Material Shipments") and the shipping papers associated with radioactive material
(RAM) Shipment No.98-067 and interviewed supervisory personnel.
Observations and Findings
The inspector noted that the shipping documents required for this exclusive use
shipment were generally well prepared. The vendor performed the calculation for the
curie content of the capsule; the results were reviewed by licensee personnel; and the
inspector noted that the methodology was in accordance with industry practice. The
shipping papers contained the information required by 49 CFR 172 (waste classification,
- reportable quantity, physical and chemical form, radiation levels, emergency response - -- - - - - - -- --
information, volume, weight, total activity, and the 95% rule for listing radionuclides) and
were signed by authorized shipping personnel.
5
However. during the personnel interviews and the comparison of the shipping
documentation with the applicable shipping procedure, the inspector noted that several
aspects of this shipment did not meet procedural requirements or management
expectations.
In Section 5.1, the procedure stated that radiation levels in excess of 75% of the
applicable limits should be verified and documented on the appropriate container
survey form. After the RMSS detected the 170 mrem/h contact radiation level
(85% of the applicable limit), he instructed an HPT to verify the radiation level at
that single location. The environmental supervisor indicated that the RMSS
should have instructed the HPT to verify the entire cask survey. In addition, the
verification survey was not documented on the appropriate form.
Per Section 5.2, the environmental supervisor authorized the extension of the
maximum radiation levels on packages above the 75% administrative level, but
this supervisory authorization was verbal and not written. Although the procedure
required that the authorization be retained in the appropriate shipment packet,
this authorization was not retained with the shipment packet.
Per Section 6.13, the consignor (licensee) issued specific instructions in writing
for the maintenance of exclusive use shipment controls and included them with
the shipping paper information provided to the carrier. However, the licensee did
not keep a copy of the written instructions that were signed by the carrier for the .
licensee's records or for inspection review. This was a concerri as the carrier
delivered this shipment to the sub-contractor and not to the engineering vendor,
which was the consignee (receiver) on the shipping papers. Although no
violation of regulatory requirements was identified, the delivery of this exclusive
use shipment to an entity other than the listed consignee necessitated a revision
of the shipping papers and the procurement of a copy of the actual receiver's
license, to ensure the sub-contractor's authorization to possess this RAM.
Section 9.3.1 required a Bill of Lading for all exclusive use shipments, and 9.3.2
. required that the Bill of Lading include the transport index for each package in
Radioactive Yellow-II or Yellow-Ill shipments. However, the transport index was
not included on the Bill of Lading for this Radioactive Yellow-Ill shipment.
Attachments 4 and 7 of the procedure required the acknowledgment of any
survey data in excess of 150 mrem/h and/or 75% of the limits, respectively, on
these forms. Although the RMSS had detected and verified the existence of
170 mrem/h radiation levels on the surface of the package, he did not
acknowledge this on either of these attachments. The RMSS indicated that he
mistakenly thought that 175 mrem/h was the correct radiati~n level which
,_,
--*- -------eorrespcfffded to the 75% limit specified on these forms.
Although some of these instances did not meet procedural requirements, the RAM
shipping procedures were not required by the plant Technical Specifications (TS) and,
therefore did not c0nstitute examples of TS procedural violations. However, the
6
~*
inspector expressed concern that several instances of failure to comply with written
instructions or management expectations occurred with this shipment.
During the interview and document reviews, the inspector noted that the RMSS had
performed the radiation surveys and reviewed the data and shipping papers. Normally,
HPTs would perform the surveys and the RMSS would provide an independent,
supervisory review of the data. However, due to the lack of HPT availability during this
time, the RMSS conducted the surveys and reviews, thereby precluding an independent
review which may have identified some of these deficiencies to meet plant expectations.
C&RS supervision planned corrective actions to address the issues identified from this
transportation incident. These plans included the documentation of the reviews and use
of vendor procedures, required documentation for any verification surveys, written
authorization by a minimum of two supervisors to conduct a shipment with radiation
levels in excess of 80% of the regulatory limits, and revision of the procedures and forms
to reflect these changes. In addition, the C&RS staff obtained the services of an *
experienced transportation vendor to review shipping procedures and practices.
c.
Conclusions
Overall, the shipping papers for the RAM shipment 98-067 were prepared in accordance
with plant procedures and expectations. However, several aspects regarding both
survey and documentation practices did not meet either procedural requirements or .
management expectations, and the lack of normally available personnel resources
contributed to these deficiencies.
X1
Exit Meeting
The inspector presented these inspection findings to members of the licensee's management
during an interim exit meeting on August 26, 1998, and at a final ~eleconference exit meeting on
September 3, 1998. Plant personnel did not indicate that any information in this report was
considered proprietary .
7
1
PARTIAL LIST OF PERSONS CONTACTED
Licensee
"
M: Banks, C&RS, Manager
J. Beer, Technical Support Supervisor
R. Burdette, NPAD Examiner
B. Dotson, Licensing Analyst
G. Goralski, Configuration Control Manager
N. Haskell, Licensing Director
R. Henry, Radiation Material Shipping Supervisor
D. Malone, Licensing Manager
D. Malone, Engineering Manager
M. Menucci, C&RS Assessor
T. Neal, Environmental Supervisor
T. Palmisano, Site Vice President and General Manager
C. Plachta, Radiation Protection Manager, Radiological Services Supervisor
D. Rogers, General Manager Plant Operations
G. Szczotka, NPAD Manager
D. Smedley, Licensing Supervisor
D. Watkins, Duty HP Supervisor
J. Lennartz, Senior Resident Inspector, Palisades
Opened
INSPECTION PROCEDURES USED
"Solid Radioactive Waste Management and Transportation of Radioactive
Materials"
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
50-255/98018-01
EEi
Failure to prepare a shipment of radioactive
material such that the radiation levels will not
exceed 200 mrem/h on the external surface of the
package. (Section R1 .1)
8
...
t
C&RS
cm
CR
EEi
HPT
mrem
mrem/h
mSv/h
TS
ACRONYMS USED
Chemical and Radiological Services
centimeter
Condition Report
Department of Transportation
Escalated Enforcement Item
Health Physics Technician
millirem
millirem per hour
millisieverts per hour
Radioactive Material
Radioactive Material Shipping Supervisor
- Radiation Work Permit
Spent Fuel Pool
Technical Specifications
9
'
- PARTIAL LISTING OF DOCUMENTS REVIEWED
Technical Specifications Section 6.4 - Procedures.
Shipping Package for Radioactive Material Shipment 98-067.
Incident Response Team Report - Reactor Surveillance Capsule Shipment.
Condition Report C-PAL-98-1533.
Procedure No. HP 6.20, Revision 14, "Radioactive Material Shipments".
RWP 980230, Revision 0, "Load Cask with Surveillance Capsule".
Work Instruction Wl-RSD-R-013, Revision 1, "Surface Contaminated Object Shipments".
10