ML20055D143
| ML20055D143 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/20/1990 |
| From: | Bores R, Joseph Furia NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055D141 | List: |
| References | |
| 50-245-90-08-EC, 50-245-90-8-EC, NUDOCS 9007050018 | |
| Download: ML20055D143 (45) | |
See also: IR 05000245/1990008
Text
{{#Wiki_filter:._ _. _ _ __ . ,' .' i I - NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-245/90-08 Docket No. 50-245 License No. DPR-21 Licensee: Northeast Nuclear Enerav Comoany P. O. Box 270 Hartford. Connecticut 06141-0270 facility Name: Millstone Unit 1 Meeting At: NRC Reaion I. Kina of Prussia. Pennsv1vania Meeting Conducted: June 15. 1990 _ Prepared By: 5 d* k /"/" - J. Fyria, Radiation Specialist, Effluents Radiation date Protection Section (ERPS), Facilities Radiological Safety and Safeguards Branch (FRSSB), Division of Radiation Safety and Safeguards (DRSS) Approved By: W (de/Pp oresf/ Chief ERPS, FRSSB, DRSS date . Meetina Summary: Enforcement Conference at NRC Region I, King of Prussia, Pennsylvania, on June 15, 1990, to discuss the findings of NRC Inspection Report No. 50-245/90 08. The topics discussed related to the shipment of irradiated hardware as radwaste to the Low-Level Waste Disposal Facility at Barnwell, South Carolina on May 7, 1990. The meeting was attended by NRC and licensee management and lasted for approximately two hours. 900705001e 900625 gDR ADOCK 0500 5 Me 2 .
- _ _ _ . _ . .
. , . . 4 . f DETAILS 1. Particicants 1.1 Northeast Nuclear Enerav Conoany P. Blasioli, Supervisor, Nuclear Licensing H. Haynes, Unit Services Director P. Miner, Engineer, Nuclear Licensing C. Palmer, Manager, Health Physics Support W. Romberg, Vice President, Nuclear Operations J. Stutz, Millstone Unit 1 Director 1.2 NRC Personnel R. Bores, Chief, Effluents Radi tion Protection Section, RI , M. Boyle, Senior Project Manager, NRR 3 R. Burnett, Deputy Regional Administrator, RI R. Christopher, Enforcement Specialist, RI J. Furia, Radiation Specialist, RI D. Haverkamp, Chief, Reactor Projects Section 4A, RI M. Knapp, Director, Division of Radiation Safety and Safeguards (DRSS), RI W. Pasciak, Chief, Facilities Radiological Protection Section, RI L. Roche, special Assistant to the Director of DRSS, RI K. Smith, Regional Counsel, RI , 2. Eurpose The Enforcemen'; Conference was held at the request of NRC Region I to di=4 cuss the circumstances surrounding the shipment'of irradiated hardware for disposal at the Low- l Level Waste Disposal Site at Barnwell, South Carolina, on May 7, 1990. Upon receipt and subsequent inspection, it was " discovered that the cask used to make this shipment contained approximately 196 gallons of water, which is in 'i excess of the limits for both the cask and the disposal site ( as set forth by the NRC. The discussions at this meeting l focused on the identified apparent violations, the root I causes of the event and licensee's corrective actions to ' prevent recurrence. 3. Licensee Presentation ! The licensee's presentation consisted of a series of view graphs and appropriate discussions. Copies of the view . graphs and handouts are attached. The licensee concurred that the items identified were violations, but strensed its corrective actions and the fact that this event has already been the subject of enforcement action taken by the State of South Carolina. l . . .-- . - - ~ ,
__ ._ - . _,
, .. . . . . 3 4. Concludina Statements NRC Region I management stated its concern that this was the third enforcement conference and the fourth and fifth violations in this area withi'. the past year. NRC Region I management stated that the licensee would be informed of the need and the nature of appropriate enforcement action . relative to these violations at a later date. ' . b 1 i 4 - ___
. -- - - - - . . - - -. ~ . . _.9o
- , , 9 g Docket No. 50 245 i v h
> Enforcement Conference TN RAM Cask Shipment to Barnwell, SC , Northeast Nuclear Energy Company June 15, 1990 t . - _ - .-. - ,
._ .' . .. 1- ..
. Issue " ...the licensee shipped a TN-RAM cask with material intended for disposal, that contained approximately 196 gallons of free standing water, representing approximately 40% of the available cask volume. The failure to comply with 10CFR61.56(b)(2) and 10CFR71.12(c)(2) is identified as apparent violations (50245/9008-01;50-245/90-08-02)." Description of Event ' On Monday, May 7,1990, a TN-RAM cask was shipped from Millstone Station to the Barnwell Waste Management Facility in Barnwell, South Carolina. On ' Wednesday, May 9, 1990, Chem Nuclear Systems Inc. (CNSI) notified Northeast Nuclear Energy Company (NNECO) that during the liner offloading operation, approximately 75 gallons of water was released into the slit trench area when personnel loosened the cask lid. Two previous shipments of similar irradiated material were successfully made using the TN RAM cask in the fourth quarter of 1989. Immediate Actions NHECO management travelled to the Barnwell Waste Management Facility to assess the event on May 10. An independent investigation was initiated by a team consisting of corporate Radwaste Systems and Nuclear Safety Engineering personnel, to evaluate the event and determine the root cause. NNEC0 management met with representatives of Wastechem Corporation (contrac- tor) and Transnuclear Corporation subcontractor for transportation) to Wastechem was requ(ested to perform its own investigatio discuss the event. into the cause of the event. During the meeting, a preliminary conclusion was reached that the cask liner drains had become blocked during the draining operation. A follow up meeting was held, with CNSI and South Carolina Department of Health and Environmental Control (DHEC) representatives in attendance, to discuss the appropriate course of action. On May ll, a meeting was held to solve the problem of removing water fret the cask. The plan was to put the cask on a trailer, draining the cask .,le rotating slowly to vertical orientation and then returning the cab. te a horizontal orientation. This process was to be repeated until no water drained from the cask and then the vacuum drying system would be used. At this time, procedure development began. In parallel, Millstone Station personnel began preparing cask handling and vacuum drying system equipment for shipment to Barnwell. The equipment was shipped to Barnwell on May 14. Millstone Station personnel worked closely with CNSI and Transnuclear on the procedure development effort. On May 16, the dewatering procedure was completed and approved by CNSI. A walk-through of the procedure was performed with the CNSI work crew. Additionally, the slit trench area was decontam- inated. The soil was removed to a depth of about 3 inches, with about 300 cubic feet removed. -- . . . - - -
i
,' 2- i ' i . Through the cooperative efforts of all organizations involved, the cask was successfully drained on May 17, and the liner was buried in the slit trench in
- onformance with Barnwell burial criteria. An additional 121 gallons of water
wts removed from the cask. DJring the above-mentioned actions, NNECO kept the NRC, Connecticut Department of Environmental Protection, and DHEC informed about the investigation of the event and our progress towards dewatering the cask. State Enforcement Action In a letter dated May 16, 1990, NNECO was notified by South Carolina DHEC that our waste transport permit was suspended for a period of not less than 30 days and that a $6000 civil penalty was assessed in response to this event. NNECO paid the civil penalty on June 5, 1990. sause of the Event The independent corporate team concluded that the root cause of the event was an inadequacy in the design of the cask liner drain system, which allowed the screen over the drain holes to become plugged. A contributing cause was a , lack of clearly stated procedure acceptance criteria. This situation was further compounded by the operator not fully understanding the dryness verifi- cation procedure. The findings of Wastethem were consistent with our conclu- sions. In addition, NNECO personnel relied too heavily on the expertise of < Wastethem regarding the technical adequacy of t'.s procedure. Analysis of Event During January 1990, control rod blades containing boron carbide (B C) and 4 miscellaneous irradiated hardware were loaded into a cask liner in the Millstone Unit No. I spent fuel pool. The liner was held in the pool until the subcontractor for the transportation, Transnuclear Corporation, made the TN RAM cask available, On May 5, the TN RAM cask was removed from its trailer and placed in a verti- , ! cal orientation on the floor of the reactor building. The cask was filled t with demineralized water using the drain line. It was then lowered into the spent frel pool where the liner containing the irradiated hardware was subse- quently loaded. The lid was then placed on the cask, the cask was removed from the fuel pool, and placed on the 108 elevation of the reactor building. L The liner drain system consisted of one hundred 1/4-inch holes drilled into L the 3/4 ii.ch bottom plate. The holes were covered, on the outside, with a 100 mesh, 316 stainless steel wire mesh cloth which is he*1d in place with an 11 - gauge filter plate with 3/8-inch holes. The drain system is intended to allow l water in the liner to drain into the cask void. A catalog indicates that the l open area for this 100 mesh cloth is aboet 30L De drain area is further
decreased by the installation of the Wastechem designed support arrangement - inside the liner to accommodate the intert for the more highly activated l radioactive waste components. The base plate for this suppit arrangement ' i covers about 1/3 of the 100 holes. .
, . .
- _ - .. _- . _ _ . - . ' , ," e =3* b l
. ~ To drain the cask, a line was installed on the cask drain fitting and run to the fuel pool. The vent was opened and the cask drained. The operator , observed water flowing from the hose. The cask was allowed to continue ' draining overnight. On May 6, after completion of the draining operation, cask drying and dryness verification procedures were performed. > A drain bottle was installed on the cask drain connection. The vacuam drying system was installed on g vent to the cask. With the vent closed, a vacuum of approximately 40 mbar was drawn on the cask. At this point, the vacuum pump was isohted from the cask by closing the valve and the vent was opened. This forced atmospherte air into the cask, forcing residual water into the collection bottle. The procedure states that this process is to be repeated until-such time as no water is observed in the collection bottle and then the process is to be repeated three more times. Upon successful completion of ' this process, the cask dryness verification procedure was performed. The drain connector was removed from the cask, the vent closed and a vacuum was again drawn on the cask. The cask was then isolated from the vacuum pump by closing the valve. The pressure was recorded and the vacuum was held for a 10 minute period. The procedure states that if the pressure increase observed is less than 6 mbar, then the cask is presumed to be dry. This indicates that no phase change is taking place in the cask. During the Millstone Unit No. 1 operation, the pressure increased from 27 mbar to 28 mbar during the 10-minute test. All of the procedural steps were followed by the contractor and veri- fied by NNECO Quality Control personnel. A postevent review of the Safety Analysis Report (SAR) for the TN RAM cask and the Wastechem procedure revealed that there was a discrepancy between the two documents regarding the proper method for conducting the dryness verification test. The SAR specified that the test be conducted at a vacuum of 10 (+2, 0) mbar. The Wastechem procedure, which was developed from the Transnuclear Cask 0)eration Technical Manual, specified a " minimum" of 10 mbar. It appears that t1e introduction of this vague acceptance criteria was introduced in the 4 Technical Manual. This change from the SAR specified value resulted in the test being conducted at whatever vacuum the operator chose, and in this instance was 27 mbar. At 27 mbar, the cask cavity vacuum pressure would not be expected to rise, regardless of the presence of water, because 27 mbar is the saturation pressure of water at about 73*F. At 27 mbar an equilibrium
, saturation state was established. Therefore, the use of 27 mbar as a criteria i resulted in the operator falsely interpreting the results of the test to L indicate that the cask was dry. This also demonstrated that the Wastechem personnel performing the test did not fully understand the dewatering / drying process or the verification test. Records from the first two shipments from Millstone Station show that this test was conducted at pressures of 10 mbar i and 17 mbar, respectively, by the same personnel. Additionally, test results from two other plants indicate that the same point of confusion existed. ' Fortunately, in all other cases the cask and liner were successfully drained. ' (1) 1 mbar = 1/1000 bar, I bar = 0.9869 atmospheres = 14.5 psia l . i . . . . . .-- -. -.
. . _ _. _- -- . . = ' 4 o . ! - . Assessment of Safety $1onificance i At the request of NNECO, Transnuclear Corporation has investigated the effect of shipping approximately 200 gallons of water in the TN RAM cask. An evalua- , tion of the weight of the water was performed. Two hundred gallons of water weighs 1670 lbs. The weight of liner and contents was estimated at between
6000 7000 lbs. The combined weight of the liner, contents, and water would be ' no more than 9000 lbs. Since the cask is designed and licensed to carry up to 9500 lbs. of liner plus contents, there is no structural concern regarding the added weight of the water and its effects on the cask. The SAR thermal evaluation of a fire condition concluded that the cold wall cavity peak temperature during a fire condition is 210'F. Since that analysis was performed ignoring the specific heat of any cask contents, ine presence of water (and contents)- would decrease peak fire temperatures significantly. However, some local boiling could occur at the SAR temperatures. This effect would be mitigated by steam condensing on the cavity wall or in the remaining The cavity pressure during the fire was calculated to be 26.5 water. assuming the presence of sufficient water to reach saturation pressure. psig The cask is designed for a maximum normal operating pressure of 30 psig and the cask was hydrostatically tested at 45 psig. Therefore, there is no potential problem for a fire condition. In addition, an evaluation of the TN RAM cask for the accident conditions of 10CFR71 showed that the accidents would not result in structural damage to the cask. This evaluation is not affected by the presence of water in the cask. The lid bolts do not yield, the cask will not be punctured, and all stress criteria are met even with water in the cask. Therefore, there is no poten- tial for spillage. Based on Transnuclear's evaluation of the three failure modes (i.e., weight of the wattr, effects of a fire, and potential for breach of the cask), the overall safety significance of this unanticipated water in the cask was minor. Based on the evaluation, contamination of tie general public from this event was not credible. Additionally, the safety significance of approximately 75 gallons of water spilling into the slit trench area at Barnwell was minimized by the excellent training given the CNSI personnel, in that they were prepared for water in the cask, and therefore did not become contaminated. The impact of the spill was mitigated through prompt decontamination and cleanup efforts. Corrective Actions / Actions to Prevent Recurrence Immediate actions involved working with DHEC, CNSI and Transnuclear to successfully dewater and bury the liner, as described above. NNEC0 promptly issued a NUCLEAR NETWORK entry to alert other licensees to the potential for similar events. In addition, two other plants where the TN-RAM cask was used were individually alerted to this event. We can say with considerable confidence that this event is not unique to Millstone Station and has the potential for affecting other licensees. NNECO believes that issuance of an Information Notice to all licensees to further alert them to this event would be beneficial. . . . . - - . . . .. - -
.. - . i o . 5- , . o t . .
. , Wastechem will incorporate multi-layered filtration above the drain ports to prevent loose particles from blocking water flow. Wastechem has also initi- - ated the following procedural changes as a result of this event and will train
its operators accordingly: o Require that the water drained from the cask be quantified and compared to the volume of the contr.ner, Make the dryness test consistent with the Safety Analysis Report by o- specifying that the dryness test will be done at 10 (+2, -0) mbar.
o Add a precautionary note regarding the interpretation of pressure plateaus in the cask during the dryness verification to give the operator an appreciation that water might still be present at a higher pressure. o Add a contingency dewatering process to address situations where it has been determined that the cask has not been successfully drained through normal methods. This would be similar to the procedure used at the- Barnwell site on May IL
To prevent the recurrence of events of this type, NNECO will develop a proce- dure to ensure that future irradiated hardware shipments will include provi- sions for water accountability in procedures regardless of liner design / vendor
by July 31, 1990. NNECO believes that the corrective actions described above will be effective in reducing the potential for events with a similar root cause. To further improve the overall quality of the radioactive materials transpor- tation program, we have undertaken an independent, comprehensive and critical review of all radioactive materials process procedures currently in use, to specifically identify all regulatory objectives and to evaluate the adequacy of the methods used to satisfy these objectives. This review has begun and is expected to be completed by August $1, 1990. Our review of the event at the Barnw311 site was not limited to the actions immediately preceding the discovery of water in the cask. One of the areas
that we reviewed was vendor selection for radioactive material handling and f transportation services. NNECO examined the selection of the vendor very
closely and reexamined the proposal, qualifications of personnel involved, and I track record for similar services. The vendor had previously been very i successful at providing the required services, thus providing NNECO with a high degree of confidence. NNECO believes that it was reasonable to have i relied on the vendor as the " expert" regarding the proper operation of the ' dewatering / drying system. However, the degree to which we relied on the vendor for providing these technical services resulted in NNECO not identi- 1 fying a problem regarding the clarity of the acceptance criteria for the vacuum drying equipment during the dryness verification process. Our reviews of the vendor's procedure focused on the compatibility of the operation with other considerations, such as heavy loads and movement within the spent fuel pool. The review also identified actions to be taken by the vendor that would satisfy cask Certificate of Compliance requirements. This information was then used to identify QC hold points requiring inspection. ] , - l _
. . - .-. _ - - _. . ._. . -_ , . 6- ,
.
. ~
Looking back at the reviews which were done, we han identified an addiiinnal action that could be taken, beyond those which afdress the specific root cause, to improve overall performance in the future. NNECO believes that for future radioactive material transportation related processes, a detailed j technical analysis of the process control procedures 't necessary to specifi- cally identify ?" . transportation and other regulatory requirements will be satisfied. Eml W will be placed on quantitative meaeres taken to address such criteria, b formal review will be the responsibility of the Health Physics Support Department. The procedure / checklist wili be in place by July 31, 1990. We believe these initiatives will furtha strengthen the radioactive materials transportation program at the Millstone Bation. Unit Responsibilities One of the ident'fied weaknesses contributing to the Barnwell shnping event was that NNECO relied too heavily on the expertise of Wastechem reprding the . technical adequacy of the procedure used to drain and dry the cask. A lesson learned is that NNECO must identify the responsibility of the unit ad how ' that relates to the responsibilities of the Radioactive Materials Har.dling Department. The lines of responsibility in this case were not clear. The overriding theme is increased accountability, ownership, and responsibility for shipping of radioactive material from the units at the Millstone Station. Several years ago, the individual Millstone Station units had the responsi- bility for the planning, control, and implementation of all activities relat- , ing to shipping of radioactive materials. The Millstone Station subsequently - developed a radioactive materials handling group which specialized in prepara- tion, packaging, and shipping radioactive materials. As the units' confidence in the group grew, their involvement became significantly less, which dimin- ished the units' ability to assure the overall continuity of the process. Millstone Station management recognizes that this factor contributed to the Barnwell shipping event. Therefore unit personnel responsibilities for overall planning and control of all activities relating to their respective unit, up to and including any offsite shipments of radioactive material, will be reinforced. They will be supported by radioactive materials handling > personnel, whose specific job task is to safely package and ship radioactive materials, end other support groups as necessary. NNECO believes reinforcement of this definition of responsibilities will have a positive I effect by providing continuity by unit personnel during the entire job process. ' Radioactive Materials Transportation Procram l NNECO has identified corrective actions that will be taken to prevent recur- rence of problems similar to this event. In addition, the vendor is redesign- I l ing the filter for the drain system and has initiated procedural changes developed in cooperation with NNECO, to assure that the required dryness is obtained. It should be noted that WasteChem implemented the procedural changes at another plant and successfully dewatered the cask. Finally, NNECO - _ . --
. - _ _ _ _ __ _ . _ _ __ l .'
- 1*
, < a has gone beyond corrective actions and is implementing two initiatives to ! ! further strengthen the radioactive materials transportation program. NNECO recognizes our overall responsibility for this event and have therefore i evaluated all available information in development of corrective actions and program enhancements. Moreover, we expanded the scope of our review to include other recent events involving radioactive material transportation issues, i.e., the shipment of a contaminated hydrolazer, the limited quantity shipment of ladders and a fiberscope, and the shipment of an underwater shear cutter (USC). The hydrolazer was not identified as being contaminated and, therefore, never i became subject to the controls of the radioactive materials handling program. The violation associated with the shipment of the ladders and fiberscope was ' caused by inadequate preparation of the package for shipment in that movement of the equipment within its container was not prevented. NNECO took reason- able Steps to decontaminate the USC prior to shipment, but it arrived at its destination with radiation levels on the surface of the package in excess of DOT regulations. This incident was caused by NNECO incorrectly concluding that all major hot spots on the cutting unit were eliminated or fixed and therefore not removable. All of these events are of concern to NNECO, however, we have not identified a singular or common root cause. For each of the events briefly discussed above, NNECO developed and implemented appropriate corrective actions. While we believe that the corrective actions should be effective in preventing recurrence of similar types of events, we also believe that several of our initiatives will also strengtnen and improve the overall planning and control of activities involving radioactive materials. This is discussed below. - As a direct result of the release of the contaminated hydrolazer, a compre- hensive review of the entire program for release and control of rediological material was initiated and several procedural changes were made. Of specific interest is that Health Physics involvement in the planning and control of the work process was increased through a heightened awareness of responsibilities. In addition. Health Physics personnel were given the responsibility for surveying all items leaving the radiological control area to provide the unconditional release. NNECO took the first step towards increased radioactive materials handling supervisory and management involvement in the work and formal review process as a result of the shipment of the USC. Procedures now require that addi- tional preshipment supervisory review be performed and any additional controls specific to a shipment be included in the inspection plan which is reviewed and approved by the Health Physics Support Manager. The above actions, - however, were limited to shipments with a high potential for hot particle migration, in response to the TN RAM shipment to Barnwell, NNECO will expand the scope of radioactive materials handling personnel involvement in the work planning, control, and review process through initiation of a formal review process which will identify the quantitative measures taken to address how transporta- tion and other regulatory requirements are satisfied for future radioactive material shipments under the control of other departments. . - - --. . .
. . ._ __ _ _ i ' 8
.. ! . ' . A Coupled with the independent critical review of the existing radioactive materials process procedures, the above mentioned actions provide a compre- hensive response to the recent transportation events. Additionally, NNECO is adding a senior engineer level staff position to the Health Physics Support department. This individual will be responsible for ongoing program assess- ment and will maintain a more global perspective with respect to the radio- active materials handling and transportation process. We believe the addition of this position will increase the technical ex>ertise in the department and lead to a better overall organization. NNECO believes that upon completion of these activities, the potential for shipping related incidents such as those which have recently occurred will be substantially reduced. Summary The root cause of this event was an inadequate liner design, in conjunction with a lack of clearly stated procedure acceptance criteria. This situation was further compounded by the operator not fully understanding the dryness verification procedure. Notwithstanding these inadequacies, NNECO fully understands our responsibility for this event. , NNECO was confident, based on past performance, that Wastechem could adequately provide the required technical services. NNECO believes it was reasonable to have relied on the vendor as the " expert". However, the degree to which we relied on the vendor resulted in NNECO not identifying a problem
regarding the clarity of the procedure acceptance criteria. It is noteworthy that this procedure was successfully used at two other plants, and at M distone Unit No. I prior to this event. Fortunately, in all of the previous shipments, the cask and liner were successfully drained. Since the procedures and liner design used for the Millstone Station shipment are not unique, this event has generic implications. NNEC0 believes that issuance of formal notification by the NRC to all licensees to alert them to this event would be beneficial, i NNECO took prompt and comprehensive actions to prevent recurrence of problems similar to this event. In addition, we performed a more global review of this and other recent transportation-related events. Our response to this event, goes beyond current actions and include two initiatives to further strengthen the radioactive materials transportation program at the Millstone Station. The first initiative is an independent and comprehensive review of all radio- active materials process procedures currently in use. The second initiative involves a procedure / checklist which will provide a detailed technical analysis of the process control procedures which will be used for future transportation related processes. The above-mentioned initiatives will specifically identify how transportation and other regulatory requirements will be satisfied. . As previously discussed, the State of South Carolina has taken enforcement ' action against NNECO by assessing a civil penalty of $6000 and suspension of our waste transportation permit for 30 days. NNEC0 has been verbally notified that our permit has been reinstated, effective June 16, 1990. .
y. __ __ _ ._ _ _. ! ! ,' 9-
o , . . . - i , ' In summary, we believe our initiatives, in conjunction with the senior engineer which is being added to the staff, will further enhance the > effectiveness of the radioactive materials handling program. Furthermore, by defining the responsibilities of the unit personnel, we have better assured continuity of the entire job proceis. Therefore, the potential for shipping related incidents will be significantly reduced. t NNECO remains committed to transporting radioactive materials in a consistent- ly safe manner. With our continued attention and commitment, NNECO is confi- dent that the quality of the program will become more evident to the NRC Staff. , p i ' . .
- - - - - .- . i ' . . i 4 . ! TN-RAM SHIPMENT TO ~ ~ ' i ! BARNWELL, SC l l t ! mwHafeme ' l Nuolear Power Station I i . MEETING WITH USNRC ! ' i KING OF PRUSSIA, PA i JUNE 15,1990 l
. ' l l ! ! ! . . . - . _. .- - . . . - - - . . - . - . . . - . .-
-- -- - . .. . , 1
- ..
- 1 , NU MEETING ATTENDEES ~I ~
i ! < .: Wayne D. Romberg Vice President, Nuclear Ops. John P. Stetz Director, Unit 1 i . 1 Hatty F. HaYnos Dimctor, Unit Services L l Charles R. Palmer Manager, Health Physics Support
i i l Pau1 A. Elasioli Generation Facilities Licensing
' i k ! , I '
i ! !
i l i ,t 1
_.
- - . . . . . . AGENDA ~ ~
i i INTRODUCTION WAYNE D. ROMBERG l l ~ l OVERVIEW HARRY F. HAYNES ' DISCUSSION OF EVENT CHARLES R. PALMER j UNIT RESPONSIBILITIES JOHN P. STETZ RADIOACTIVE MATERIALS HARRY F. HAYNES TRANSPORTATION PROGRAM i SUMMARY WAYNE D. ROMBERG ! ! ! l
I i ! ! ! - - - i - -- - . . - .. - . . - . . . - . -
- - - - - - --- - - - - - - - h
. . . ~ JOB OVERVIEW l ~ , i IN FALL OF 1989 l
- WASTE CHEM CORPORATION WAS AWARDED A CONTRACT
f
! TO DISPOSE OF UNIT 1 CONTROL ROD BLADES , . AND MISCELLANEOUS IRRADIATED HARDWARE.
i !
- WASTE CHEM SUB-CONTRACTED. TRANSPORTATION TO
, TRANS NUCLEAR, THE OWNER OF THE TN-RAM CASK. i
- THE WORK BEGAN IN DECEMBER OF 1989 AND WAS
COMPLETED IN MAY OF 1990. A TOTAL OF THREE j '
SHIPMENTS WERE REQUIRED. ! 1 f !
! 1 . ! \\ .
. .. .. _ _ __ __. N i < - . , ,
. . EVENT OVERVIEW ~ ~ ! l . 4 i JANUARY - THE LINER IN QUESTION IS LOADED i e l WITH IRRADIATED HARDWARE. ' !
- MAY
- CASK LOADED AND PREPARED FOR l ! SHIPMENT. I
!
- MAY 9
- NU NOTIFIED OF PROBLEM AT BURIAL SITE. HAYNES, PALMER, AND TULBA ! i DISPATCHED. ,
e MAY 9 - NU, WASTE CHEM, TRANS NUCLEAR, i to CHEM NUCLEAR, AND DHEC PERSONNEL - l MAY 16 EVALUATED THE SITUATION AND ! i DEVELOPED PROCEDURES TO PREPARE i l THE SHIPMENT FOR BURIAL.
- MAY
17 - LINER SUCCESSFULLY DEWATERED AND l BURIED. ' ,
NU NOTIFIED BY S.C. DHEC OF ENFORCEMENT ACTION.
l ! ! - - - - - . - . - . - - - . . .- . . . . . - - -
- - - - _ - _ . _. ._- _- . . ~ ~ EVENT DESCRIPTION
- CASK DRAINING / LINER PLUGGED
i CASK LOADED VERTICALLY AND e TRANSPORTED HORIZONTALLY l
1 CASK COVER UNBOLTED ALLOWING
<
I WATER TO ESCAPE l l l i f I i , I l l '
. t
_- ,- { . , ~4 . ,,- "l - - . .- - . . . .._.. . . _ . _ .. . - t . . _p . . .# - . . . . . A ' . , k. e, ' , - . .l_ ' ... . . . . - ,e gh " - d . L y . . . + -
. ..L t . . . _ g . ,.# . - - - Len . . .. . -.i
4 . . . j . e ~ . . - 4 - , , ...
- ..
. . . . g,. . ~ .- - . - ' , g', ' .. ' '
' I. , . ..\\ .- . . ..W.- y. . . . < .. t 1 .- . . . . . [ lp. . . : -. ' l' . . . , ' ~l } [ lf ; ' '. ': ' - .:
- - -
- y .
.
- [
- 3
.. ' "w ' - , . - , k' - < ' _ -
.
.
_ ~ ' . ' ' _ . , - - . . -
- 4
. , . = > .. > , , 1
' , 1 - .f. , . + ' * _
- -
< " '. . ,, i 2 ., x - [ . . , , . , .
% > r. ' 4 'k ', % . _ ' , >' ., . ; 9 . . . . . - . . . . . . . . . N -. .. '. .. .. . . . .: . ... - . . . ' ' _ _- -___ _______
( f l
. .g . 4 . es 4 % . . . . .. . 7 7 3;. ,.y7.. . , ., 7 ..% _ ' r...~r .,7 ,. s.,.,., v . <: , ; , , < , L . ,j . . .. . F1 . < . , <
e , , . ,-em, , ,y ,+#.;.?,,., . , ., , , ,yj , , . e . . c ,/ '. . , ,.. ', , t , . v . v , v.. v., / cA . c,- " , . . , ,; .
- '
O , ' , ' ' < , w?,c;,. . cE e, i , .v,. .e f ,c, . /? v '/.y/. OO
M ,;9;g:grgqQ;" h",klidis; c'c',[ ag , y , . : . . .? . < .v i 5... .",.',;, < : . ~C ,e n h ' < . ~ .
'.,'a'.. - r- 4 ,<3... ,< . yg ' ..,,se , -- r - , a -,.- . . .e O $5c \\ g , d% O N O I W uW. .a ,a . O 0 0g e _n O C > 0 >O . i k D e .2 @ 9 gE M o M Rmm e- -e \\ - - C Nk 2
- a 'D
@ O a r,. v . , , . ,, v: , . , < , ,. s M (:v., , , ., s 9 v , - M =- ,. o. s,o __m w .,y, - v oe , t/3 u a ww 1;r,.; p" U 0 'a I )o W.3., m. i - 5
- ! . a- [m , a - <,. f > e .o ma t,; ; . < N,:q , , e..c \\ ;,y //?.? ,c1 ', q; -Oc . m W/ 4.ew , r. ue=, e V > , j -o (4; g*j, - v og gh eop, k,"?p7,)'. *g/ j g =j g 9.s y O , Oi / t -e> . 2 M. . + l % O - .e E N. ,c'.+ r . .,+w. v. w A;< ; E .- J:4:4 X o g e . . . . - ,e i. $% b .. ' Y W.e '.!ve r ....> M
- o w x m w m w,e,..s
L .a.m . .v e. ,\\e,. w (3 %sw o.v. 5v.vi t s < ie. < , i .ex
- 1
Y X K X X T - m.vrt wxwt ,n. y"s ,v. - f?f>* a %vi/ e"p,", en . w enw ,, e , ,,"a W <y %* x a .' 7 'rO< /x"r"/,", ,*/ " x, v w",vx','/ .w ,O. ww. - / c H.p f/,w y/ ,, v// , .Yv , . / WE/.VY3..u. u .<- . D.g. ' A;, Or Wv. .O hin k" v.vN' ' i Qvy ' r'(O_ 1 - 's ?/ V,V,I, D, T.M M /, % ,' 'g'r r 4 'QN 4 a ' N ' b- / ' ! 1 1 4' 6
L 2 L X J: X I.::::,, w r a . m
- ; ; L . a
. n a , a 3 g 7 - - - - g _ ; = ~ - -
- .: _
.g .. EVENT ANALYSIS e " LINER DESIGN CONSIDERATIONS
PROCEDURAL CONSIDERATIONS = SAFETY SIGNIFICANCE = 2 - . _ _ - - - - - - - - - -
_ , .. . EVENT ANALYSIS
- L.INER DESIGN CONSIDERATIONS
e PLUGGING POTENTIAL = DRAIN HYPOTHESIS , . _ . _
- ,. . , . n . Cutaway Side View of TN-RAM Cask n > and Liner Cask Vent Connection %:1 ~ L x * LK'l * a J*21$ " w. k & ' ) ,$?,/ 4 ^w??$, ) r s y
, , . ,, a 4 5g$T 5 T - , .m. A . t ~j - 4 .' ' $<>i .h . i . . .. 3 ,y, , r . p- < . ' - h;h! Y ?E, 37g Cask
. .. "*# ),1 Bis .
- l'
-Annulus ' i -
- i' i , Area ' 3 j kn. . . k u .v
g , + . 'i l "- Liner b l ' .. __ Seldown l b !! Pads . L W<K Drainhole i b Pods I wa m- m e.i .e c
i E+Hm+B Rotated 1m View *316M*}X*M<4
- M4*M*MR I
M:tc:0L "t!.L,L1 - sRR44~ " h - < r<rm*X<+ , m.m v . Li^d$TNfl. " 1D*ME "{ Cutoway &X4Fra !UJ . 91.. + %,0 t ,$'0X:Xc V1tw ii = *piot End l FM&M+M *MH+C+ ! M " " itYfRY5t?:YL _, . _ . _
i.N orain connection mmox.: wn=+aw+xmex= 18 M E'!$ 3E83 5NSR M M From Cask L I 1; .Y l. 1 1 , > ,w e 4 , . , , , . . _ _ . , . , . , . . , _ - . . . m . . . . . -
_ _ -- . _ _ _ . _ . . - _ _ _ _ _ _ _ _ --- _ _ . - . _ . . _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ . . - _ _ _ . _ 'll M - .c , . . . \\
.
C W i ) - gn O C
M g g u ,, y C n aO ~ @ $ ab C EO c o << amm a- - M . A C O, -w .::.. D- Q:C - '" E=e g lO3: M s V
O M - '
- a
- bbg 2 mrm W o A h XM+>k5+ = M v '46)ME+XWA , 4
- sF5kR3#83
g g EdLg3'4{+ < 4' - , p +:4&AF 6' y . g x +'E .x um , 1 s l 9XM .g,g, YA M*:4GPBEM' o" ( < o
o o00 ' K*M*>Me' \\ ,, h l Y AWA%khY 0 o o o o
o gX 46MM M+gM w ' o OwM oooo WK4## { cooo i:m+> . , ) M9)Wk[+4 6g. . =M - 'N h* $Ml .} g NNk A >iggg g3 I \\ w gN4N+S4 h E, w*+ & K m:-5fftY:1 +_.h.M46' 2.' MM+M l, a , D. i- , x m- - x sx-y , ooo ooo gMM+$ l c !?N?N91M " L =x+m a ~ =xt: , ' [,Q $9M+SME _ .s ,, g' o ~_ :4X+C+ 'M g o
1#40VWR o !
! _ :USiiY55
i b VGOMO94E x xx EGM{+MM' 0 O %X ^ :=X ooo N N 000 g@ f ' %%556E6 $ ? kb?%. NY glIl g ' meese+we
- _
,,,,, U $EN=Nkb. HEE o- Ww +===+=+=====+!# y,- mpr -._.~- _---_ $ h ?_ Y k a me.a x w ie,ch 1J7=,t==-o m.m.- w. .m-m
m a 1 -- - - _ _ , > a v.- , - e, ,, -
w-.
- - - - _- . . _. - , . . . . . . . e,. ' Iliner Drain Hole Configuration - . , . (Cross Section of' Drain Holes in Liner Bottom) i , ., . it holes I I I l/ . '/gp -
i-
.; 7- l ( .- , '/ - l ~ / > /- 3
7 f - j j j j ////
- mmi
'-'w m v l w s.
m
- umy ;y
- p . . . . . i i i i I i j
100 mesh cloth- 3/4' steel plate j 3/8" holes 11 go. steel plate l
! > h ?
' i ! ! , i ! i l - . , . . . , - . - , . . . . .
. - ...v . ..
- -
Cutaway End View of TN-RAM Cask, Liner, and Insert Bottom ' " - - . .. . . . ~ U?31*.. d1 emoxm+wxmn 4 a l !$ Cask ' y o A- lIl V//// - . 4
i - / 4:E+oez .. , J!hfhhl f. ' " o o 4. fjyjj{{ i 5 7 Annulus l o o o , $4 ;? y-pw3
Area i o . . hdsE!E ese; 1 X*X+X E / = i y,,v bv Liner t y V = a hhg /2 h Seldown ! $5st g ,@ Pads p@:50L A141 I
hisi: o o o o sm.:- . Insert
w;:o:vtggg a o y'* ~-]g % % Jip'# -Bottom
J9hfW:m<# ' Plate !
- ===
g g coo. !!!lli I $ C^ 30$$ t ' h!!!spes!iefl$s ths;&.x. mmt .womaxsomxcax+w be<+>xe4psw vsew astfitt483Mn)V< -Lifting Lug 'Tf '"46s!09594$$t## d wmmoxa+xmumm43:mer l NtR:t::stt::pgger (Typ.1 of 6)
l l !
! ! 1 o . . . _ _ _ _ _ _ . . .,
. . '
. . l -_ _ . __ , ' i ~ p . . . < , ,~<*e- f. l , . , 9 ' -
. . . ~ , , ~ , . . . - --. - ~ . . +. . . -- - - . - - -.-~~-~.----~~~~-.a~un. < en -w.-ea- a- ~ n e- n. e -a -a m.~s~a--.-a,-.mr. .a..e~. ~.a ..u..~n..on-.e..-s-.r~ -, t ii \\ Q $ '# l. . G. , = .I .4 ' - . i
1 L
- -
!
c ' oe g e, - . e 1 ,' e 4 . g- O 4 e
- -
e g+My
e @ 4 p*o, !e/e gM e*#e, '#' . / ./p . e , 'e 9
4 - e e e / ie * P '
- .
v. u. ,. s. . ,e? ' .e. a, e .,9 - ~- .. . . . - .. .. f .- (' ,
- i
. , .e
- W-
' 3
- 3
(
- f ' ',
') t s'y
s , 4 < .+,. . .,u _ , +* " p' ' # ,, ~h', #- [ ,k* ,, ,. L,N .:bh : ,9 9,;9.o . '
- c
, . ,. . . . - , r ,, s , m- n/,a q;.:4.?v-EIJA Y . A ,. s.s **
.jr e ' - As:;v. .. . o w-t . ~ ' wrg
- .
'd' ". 6. 1 E,T. ' . . . . .,, - . ..[ )*' .
-. , e , . ^ - g m ,._ . l i ' u
_. ,a o m .. a T- r e v erT M e v .m .-m-*- ae->m--.mw-. - ---- - - - - - - - - .----------
9 !i! , i . !
!! i i; f
- !
. k e
e , 7, . g 1 , - g . - w N r w . O ITA . s )d C -, v. I ~ ' F - , s - t IT n N - o A (c S U N Q m O f I S T G , N I A N r O - S R I E NI X T D IA A I I - S C ., A N DF RI N O IR C F A O V E - LA E ., . S T R CS . - k. - N U NE - - ., D EN a w E E SY , - ,._ _ V C BR _ s O AD E R + . . P 1 2
s y .! ! . .1 ! ! , .
- _ _ _ . . _ - - - _c - t .; - - _ . - . ... . . . . .. 4 %.< ~ ' vacuum voi,e (v-4) VDS in Drainage Verification Mode- ~ ' - - - connector- . ' b. ' r , Geseous. ' l i R a d w aste ' '
System r i
t
-
[
t .... . . . . - ,
!
i .
f
, !
. ,
. '
- ! .
- t
- /- Gesgo (S-2) ! - . . l . . O . , .
l .
, , Velve (V-4)
! . -t l i ~. Filter ! . ' ' vec===-
Pump .
- m . I - Velve (V-7)
! l - - mamums ,
l - ; ! l [
Drain Vetvo (v-s) I i
Connector . . . . . . . . - --- ^ @ ' " -- -Dr in VDS Pump Skid Bottle , ,c-. . . , , .A - - - .- ,.y> .. ., ,.,y.,_,,~ ,.,. ,n, - - a .- ; '
, . .
' ji it > - ?, , -
! [ti!ii ,. , l1) l lIl,
.. a .y ~ . , - - -. , . - - . - .- se m t . . .I . nsm !. -
.l' - . 1 . oa e - uewt n s s ap ady )4 sm e gas ) - e u d R 2 V cP - o - o G V ( ( o M v e l g o , g u V i - a m n S s ) i 7 , y -V . r / D' ,. ( ev ) m l 6 s e - V V a u y ( u ov c l a x _ J o r V V' e . t l i n e % F S - m .i D - V . )4 -v ( ev ioV r. 0
.. mto . r .
.:
- :. : : :i-
- : . :- ..:-
. . : : eg . c u - u . c n . . : an vo '. . . . ., . ~. , C ' . - . . . . . . .::;.-
- -
- -
- .. :::: :. .
. , . . - - - - - . ~ -
.1 .
.. ~ . - - ~_ ~ . . --_-_....- . . . . -- . . . - - . - _ . . . - . . . -i - ,. -$ 1
6., , . ,' ), tl N . .N- ' 0: y - v.. d ^ - 1 I O- _ 1 e -o ,.
y o- , . - ~ - See f . ' @ . 54 .Q i .g- v i Q, 3l gm .g 4 ' t - p n. . t , d .!! ~$ 0 2 t . . . , ,- Q. d 6 s a o . , @ g ~$ $ l $ =O aO N $ ! m ~ g m , 8 8 s s a i O u 2 o o o o e, o o a o e- e - n - - g I ' o 1 w -- e - -1.." .2 + - -- A . t - . - - . - -- - - .
- - -- - ... 'd. TN-RAM Cask
Vacuum Drying Verification Test History a Initial Final Shipment Pressure Pressure (mbar) -(mbar) Plant #1 20 22 Plant #1 16 19 Plant #2 13 17 i Plant #2 15 16 Plant #2 17 18 Plant #2 15 15.5 l Plant #3 10 15 Plant - #3 17' 17 Plant #3 27 28 l ! l . . . . . - -
. _ . 1 7. i SAFETY SIGNIFICANCE El a ! i i . TRANS NUCLEAR EVALUATION , L WEIGHT OF WATER
THERMAL EVALUATION OF FIRE CONDITION j , l
STRUCTURAL INTEGRITY FOR ACCIDENT l CONDITIONS l l
OVERALL MINOR SAFETY SIGNIFICANCE l ' i BARNWELL SITE
l
PERSONNEL TRAINED AND PREPARED FOR l WATER
l l SPILL IMPACT MITIGATED THROUGH CLEANUP EFFORTS
l . .----1 - - - . - -- - - . - -- . - . . . = -. . - - - - - .- - -- -
.
.. . -- ROOT CAUSE
- 9
1 Inadequate liner design, in conjunction with 1 a lack of clearly stated procedure acceptance criteria, allowed the water to- be trapped in i the liner and subsequently shipped offsite. This situation was further compounded by
! I the operator not fully understanding the
dryness verification procedure.
J -
In addition, NNECo personnel relied too . heavily on the expertise of Waste Chem j regarding the technical adequacy of the j procedure. q _ $ i i _ _ _ _ , _ _ _ _ _ _ __
- - - -
- ***
, ' ..
- 1
- . Corrective Action d .
- Corrective action was completed with the
' ;l burial of the liner as previously discussed. 1
Additionally, NNECo published a description l
of the event on Nuclear Network.
, I i ! ! l f . i i > ! ! i .r -. ,
. ' j ' - - .,,;. l - > l Actions to Prevent Recurrence 1 i - , l Waste Chem l i Design - Waste Chem is beginning a redesign process that will improve the liner drainage system. l Procedure - In all such shipments, provide a ' means to quantify the amount of water drained. - Correct the dryness verification procedure discrepancy. a ] - Precautionary notes on plateaus. !
- Contingency dewatering process. - Operator training on procedural ! changos.
1 ! - - - - -- -- - - - - - - - - - - - - - . - - -I
_ -- __ _ _ _ _ .. - ..-- - - -- - . , ,1 - - - -u RADIOACTIVE MATERIALS TRANSPORTATION PROGRAM V i., ! ! EVALUATED TiliS 'AND OTHER RELATED EVENTS j e , e SHIPMENT OF CONTAMINATED HYDOLAZER I e LIMITED QUANTITY SHIPMENT OF LADDERS l l AND FIBERSCOPE ! ' e SHIPMENT OF UNDERWATER SHEAR CUTTER
= LOOKING.FOR POSSIBLE COMMON ROOT CAUSE j .
.! , - 1j i l . . . - -. . -- . - - = - . . - - - . - . . _ _ _ _ _ _ - _ _ _ _ _ , , - - -
. - = _ , _ , ., CONTAMINATED HYDROLAZER SHIPMENT 1u s . EVENT DESCRIPTION ! INADEQUATE CONTROL OF CONTAMINATED MATERIAL o < i
CORRECTIVE ACTIONS TAKEN a
e REDEFINING-HP RESPONSIBILITIES FOR FREE RELEASE l , e REDEFINING RCA BOUNDARIES e REDUCING RCA ACCESS / EGRESS POINTS ,
- IMPROVING WORK CONTROL PROCEDURES WHEN
INTERFACING WITH: CONTAMINATED OR POTENTIALLY. CONTAMINATED SYSTEMS ~ ] e INCREASING HP AWARENESS AND REMINDING PORC ' MEMBERS TO ASK 'WHAT IF' QUESTIONS
'
J ! ! ! ' _ . _ . . . . -.. _ _ . . . . . _ . . . ..-
. - . - . _ . . . . LIMITED QUANTITY SHIPMENT '
' , f 4 EVENT DESCRIPTION I m ! INADEQUATE PREPARATION OF PACKAGE = j, CORRECTIVE ACTION TAKEN ' ! e i i ! ! AWARENESS.. TRAINING FOR RMH PERSONNEL h i e ! PROCEDURAL ENHANCEMENTS ! e ! ! ! I i l > j _ i
, , - - . ..
. . ',, '
- .-,
.- UNDERWATERESHEAR CUTTER SHIPMENT l 1 l m EVENT DESCRIPTION . INCORRECTLY DETERMINED HOT PARTICLE IMMOBILE = y . CORRECTIVE ACTIONS TAKEN 1 = a '
INCREASE RMH REVIEW OF HOT PARTICLE ' SHIPMENTS '
PRE- SHIPMENT SUPERVISORY REVIEW NOW t REQUIRED ! i ! , i b i ! > - - . .. -, - . - . . . . .i -
--- - - - - _ _ -
_ -- _ ---
_ _ - _ --- - - - - . _ - . ._ _ . ..
- ,
.ev REVIEW RESULTS = CORRECTIVE ACTIONS FROM PREVIOUS EVENTS WOULD NOT HAVE PRECLUDED THIS EVENT = . NUMBER OF EVENTS DISCONCERTING 1 i ORGANIZATIONAL INITIATIVES e ! INCREASED RMH TECHNICAL INVOLVEMENT I = RE-EVALUATING ALL OPGOING PROCESSES. = TO ASSURE COMPLIANCE WITH REGULATORY CRITERIA J DEFINITION OF LINES OF RESPONSIBILITY =
p. - .. .. , . . - - - _ _ "J 7 ) 4-- a ts: 1 SUMMARY . ROOT CAUSE l = q PROMPT CORRECTIVE ACTIONS 1 . = l COMPREHENSIVE CORRECTIVE ACTIONS TO a , i PREVENT RECURRENCE , i GENERIC IMPLICATIONS = . GLOBAL REVIEW OF THIS AND OTHER TRANSPORTATION
= RELATED EVENTS POTENTIAL FOR SHIPPING RELATED INCIDENTS = SIGNIFICANTLY REDUCED- STATE OF SOUTH CAROLINA ENFORCEMENT ACTION = I _ . - - - r ' - -- -- = = L = --- " ' " ~ ^~ ^
. . . . .. . .. , y ..ai . . .. Actions to Prevent Recurrence 1 NNECo ! Program ! Initiatives - Develop a procedure / checklist for the H evaluation of new processes to ensure I compliance with regulatory requirements, e.g., water accountability. - Specifically request a complete review, by Radwaste Systems, of all Rad. Material Handling processes at Northeast Utilities to evaluate the adequacy of methods for assuring regulatory compliance. - Unit responsibilities. -- - - - - . - -. -- ___ _ }}