ML18068A486

Submits Response to Violations Noted in Insp Rept 50-255/98-18.Corrective Actions:All Shipments Temporarily Put on Hold Until Radioactive Shipment Resumption Plan Was Completed

ML18068A486
Person / Time
Site:	Palisades
Issue date:	10/30/1998
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-98-18, NUDOCS 9811090156
Download: ML18068A486 (12)

Text

A CMS Energy Comoany Palisades Nuclear Plant Tel. 616 164 2296 21780 Blue Star Memorial H1gt1way Fax: 616 164 2425 Covert. Ml 49043

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Site Vice President October 30, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018 NRC Inspection Report 50-255/98018(DRS) dated October 1, 1998, transmits one apparent violation, which is being considered for escalated enforcement. The apparent -

violation concerns a radioactive shipment which arrived at its destination with* maximum external contact dose rates in excess of that allowed by applicable regulations.

Consumers Energy has concluded that when the shipment arrived at BWX Technologies (BWX), the maximum external contact dose rate was in excess of that allowed by applicable regulations. Based on surveys performed at the Palisades site prior to release of the shipment, and testing performed at BWX, we are confident that the shipment was in compliance with regulatory dose rate limits when it was released for transport. The root cause of this apparent violation is the result of a defective -

shipping cask coupled with the ability of the surveillance capsule to shift during transport. The details surrounding this occurrence and the basis for our conclusion are provided in Attachment 1.

. Additionally, during our investigation of this matter, we identified a number of

-- --- --- ----administrative-practices associated-with-documentation;-supervisory-oversight and- --- -- -- -------- - - -

survey verification that failed to meet our expectations.* Our findings were shared with the NRC Inspector at the time of the inspection and were subsequently documented in the Inspection Report. These issues are of concern to us, especially since we have been working to improve performance in the Radiation Protection area. Our evaluation 9811090156 981030 .,.

PDR G

ADOCK 0500025~

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2 of these issues along with actions being taken to correct these problems is provided in Attachment 2.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

-:;?~~

Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC .

NRC Resident Inspector- Palisades Attachments

3

• CONSUMERS ENERGY COMPANY To the best of my knowledge, the contents of this reply to an apparent violation in Inspection Report No. 50-255/98018, are truthful and complete.

By ~L____),.,

ThOfTISJ. Palmisano Site Vice President Sworn and subscribed to before me this 3ot11 dayof (J~ 1998.

Mary Ann Engle, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)

My commission expires February 16, 2000

-~------------------*-

ATTACHMENT 1

• REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018

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• 2 Pages

AITACHMENT 1 REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018 On August 12, 1998, plant personnel removed a highly irradiated reactor vessel surveillance capsule from the spent fuel pool (SFP) and placed it into a Type A shipping cask provided by Framatome Technologies, Incorporated (FTI). A FTI representative was on site to assist in the loading evolution. Dose rate measurements of the cask as it was being removed from the SFP indicated a maximum contact dose rate of 11 O mrem/hr. This corresponded well with the expected contact dose rate of 106 mrem/hr calculated by FTI. The shipping cask was then transferred to the shipping bay and secured onto a dedicated flatbed trailer. A release-for-transport survey was perfomied on August 14, 1998 showing a single area with a maximum contact dose rate of 170 mrem/hr. This maximum reading was subsequently verified by a second survey. With the release-for-transport survey showing maximum contact dose rates within regulatory limits, the shipment was authorized to leave the site.

The shipment left the Palisades site on August 17, 1998. On August 18, 1998, receipt surveys performed at BWX Technologies (BWX) revealed an area with a contact dose rate reading of approximately 280 - 300 mrem/hr, which is in excess of that allowed by applicable regulations. BWX filed an immediate report with NRC Region. II. Palisades was notified of the results of the receipt surveys and personnel were immediately dispatched to BWX to conduct confirmatory surveys. Based on the seriousness of this occurrence, an Incident Response Team was commissioned to perform a full investigation.

At BWX, Palisades personnel conducted a blind survey of the shipping cask and identified an area of approximately 4 inches in diameter with radiation levels of 280-380 mrem/hr, which validated the location and measurements of the BWX receipt survey.

On August 20, 1998, during the removal of the basket/capsule assembly from the shipping cask, it was observed that the dose rate at the hot spot was very sensitive to rotational and/or axial position changes of the capsule and/or capsule basket. When the weight of the capsule basket was placed on the wire cable for lowering, prior to movement, the dose rate changed from 280 to 190 mrem/hr. This evolution is believed to have caused very little capsule basket axial movement, but the capsule basket may have rotated slightly. The capsule could have moved down a few inches independent of the basket movement at this time. Subsequent lowering of the capsule basket of

_ -~--- -less . than-six-inches-ft;1rther- reeueed-the-hot-spot-dose--rate-to-1 mrem/hr~-Slight ---~-- ---- -- ---- ------

rotational movement may have also occurred during this evolution.

Given the significant radiation level changes seen with little axial movement and unknown rotational movement, a local shielding weak point was expected to exist at the*

1

ATTACHMENT 1 REPLY TO AN APPARENT VIOLATION IN INSPECTION REPORT NO. 50-255/98018.

4 inch diameter hot spot. A decision was made to perform testing on the shipping cask to determine whether shielding inconsistencies were present.

• Radiography Testing of the shipping cask was performed by FTI on October 3 and 4, 1998. Results of the testing showed that the shipping cask contains a defect at the location where the elevated contact dose rate was measured. The defect manifests itself as an approximate 25-30 percent reduction in the expected shielding.

The surveys of the shipping cask. prior to its departure from the Palisades site were sufficiently comprehensive to have disclosed the subject hot spot if it had existed prior to transit. While some limited movement of the capsule and capsule basket within the shipping cask can occur during transit, this would not significantly affect the shipping cask exterior contact dose rates if uniform shielding was present. Therefore, we are confident that the shipment left the Palisades site in compliance with applicable regulations and that a defective shipping cask coupled with slight movement during transport caused the external contact dose rate at the flaw location to be in excess of that allowed by applicable regulations .

• 2

ATTACHMENT 2 EVALUATION OF SURVEY AND DOCUMENTATION PRACTICES A number of administrative practices associated with documentation, supervisory oversight and survey verification were identified related to this activity which did not meet expectations. These issues are disappointing and are of particular concern because focus has been placed on improving performance in the radiation protection area due to problems which occurred during the previous refueling outage. While improvement has been noted, we have not yet achieved consistent results. These issues were discussed with .the NRC Inspector during the ,inspection and are described in detail within the Inspection Report. The Incident Response Team evaluation determined that each issue fell within one of three root causes:

1. Supervisory oversight was inadequate in that the shipping supervisor performed

. the surveys, completed the documentation and performed the revie.ws of the documentation.

2. Lack of rigor in the documentation of certain details and in procedure adherence led to some forms not being completed or being completed incorrectly. In some instances the procedure was unclear.

3. Inadequate communication of a management expectation regarding survey performance led to only a partial verification survey being performed.

Actions have been taken to strengthen the radiological shipping program as follows:

1. All shipments were temporarily put on hold until a radioactive shipment resumption plan was completed.

2. All radiological shipping procedures were reviewed and revised as necessary.

3. Training on the procedure revisions was presented to all personnel involved in the shipment of radioactive material. . ____ _

4. Expectations were recommunicated regarding supervisory oversight and rigorous procedure compliance.

5. This incident was used as a case study during a Chemistry and Radiological Services (C&RS) Department stand down meeting on October 9, 1998. The case stuayproviaeaatnoroogh-descriptionoftne occurrence an-d-aiscussecrthlflesson*~s--

learned. Expectations which had not been clearly understood were discussed and clarified.

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ATIACHMENT2 EVALUATION OF SURVEY AND DOCUMENTATION PRACTICES Additionally, the following actions are planned:

1. Criteria are being developed and proceduralized for the review and approval of Type A (non-NRC) shipping casks, which have not' previously been used at Palisades.*

2.

• A self-assessment of the entire Palisades radiological protection program, including the shipping program, will be performed in 1999 to verify effectiveness of not only previous corrective actions, but also corrective actions related to this event.

-~- -----------~----~-- ----- ---- --- -------- ---------- ---~----------------

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October 1, 1998 EA 98-443 Mr. Thomas J. Palmisano Site Vice President and General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml 49043-9530

SUBJECT:

NRC RADIATION PROTECTION INSPECTION REPORT 50-255/98018(DRS)

Dear Mr. Palmisano:

On September 2, 1998, the NRC completed an inspection of your Palisades Nuclear Generating Plant. The enclosed report presents the results of that inspection. The inspection findings were discussed with you and members of your staff at an interim exit meeting on August 26, 1998, and a final exit meeting by telephone on September 3, 1998. The inspection examined activities conducted under your license related to radiation safety and to compliance with the Commission's rules and regulations and with the conditions of. your license..

Specifically, this inspection reviewed a transportation incident in which a Class 7 (radioactive) package, that was shipped by your facility on August 17, 1998, as an exclusive use shipment on an open transport vehicle exceeded the regulatory limits for radiation levels on the external surface of the package upon receipt. Regarding this incident, the inspection consisted of selective examinations of procedures and representative records and interviews with personnel.

Based on the results of this inspection, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

Specifically, your facility offered for transportation a Department of Transportation Specification 7A Type A shipping cask that had been loaded with an irradiated reactor surveillance capsule.

Although radiation surveys conducted at your facility determined that the package met the -

regulatory requirements for radiation levels on the external surface prior to leaving your facility, the shipment consignee measured radiation levels that exceeded the regulatory limits. The radiation levels on the external surface of the package were subsequently verified by members of your staff.

9810060168 981001 PDR ADOCK 05000255 G . PDR

T. Palmisano 2 The root causes of the apparent violation could not be determined before the conclusion of this inspection. Our review determined that certain aspects of the preparation of this particular shipment were not conducted in accordance with your transportation procedures or with management expectations and that this shipment was conducted under reduced management oversight and staff involvement. In addition, other information regarding this event indicated the possibility that an inherent problem with the design and/or manufacture of the shipping cask may have contributed to the violation, and we understand that your facility is pursuing an analysis of the cask to determine whether this is the case.

The circumstances surrounding the apparent violation, the significance of the issues, and the need for effective and lasting corrective action were discussed at the interim and final exit meetings. In order to determine whether a predecisional enforcement conference is warranted, we request that you respond to the apparent violation, including your evaluation of your shipment preparation practices and the shipping cask, within 30 days of the date of this letter.

Your response should be clearly marked as a "Response to an Apparent Violation in Inspection Report No. 50-255/98018" and should include: (1) reason for the apparent violation, or, if contested, the basis for disputing the apparent violation, (2) the corrective steps that have. been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response should be submitted under oath or affirmation and may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a predecisional enforcement conference.

If you have questions about this matter, please contact Raymant L. Glinski at 630/829-9725 or Gary Shear at 630/829-9876 as soon as possible.

In addition, please be advised that the characterization of the apparent violation described in the enclosed inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of the results of our deliberations on this matter.

In accordance with 10 CFR 2. 790 of the NRC's "Rules and Practice," a copy of this letter, its enclosure, and your response. (if you choose to provide one) will be placed in the NRC Public Document Room (PDR). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

T. Palmisano 3

• We will gladly discuss any questions you have concerning this inspection.

Sincerely, Original Signed by John A. Grobe John A Grobe, Director Division of Reactor Safety Docket No. 50-255 License No. DPR-20

Enclosure:

Inspection Report 50-255/9801 S(DRS) cc w/encl: R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations N. Haskell, Director Licensing R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Department of Attorney General (Ml)

Emergency Management Division, Ml Department of State Police

• Distribution:

CAC (E-Mail)

Project Mgr., NRR w/encl J. Caldwell, Riii w/encl

• C. Pederson, Riii w/encl SRI Palisades w/encl DRPw/encl TSSw/encl DRS (2) w/encl Rill PRR w/en_9.

PUBLIC~w/encl Docket File w/encl GREENS IEO (E-Mail)

DOCDESK (E-Mail)

DOCUMENTNAME:G:ORS\PAL98018.WPD * ~

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