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MEMORANDUM T0:
File (DN 50-293)
THROUGH:
P. J. Knapp, Chief, Facility Radiological Protection Section FROM:
K. E. Plumlee, Radiation Specialist
SUBJECT:
CLEANUP OF SPENT RESIN IN PILGRIM STANDBY GAS TREATMENT SYSTEM (SBGTS) PLENUM Mr. R. Trudeau, Pilgrim Station Radiation Protection Manager (RPM) provided the following information when we contacted him 'y telephone, at 5:15 p.m.,
on o
i February 1,1982.
A.
Spent Resin in SBGTS Inlet Plenum 1.
About 80 to 100 gallons
- of spent resin was removed from the SBGIS inlet plenum on the evening of January 28, 1982. Mr. Trudeau said it was discovered earlier in the day but may have rested undetected for two or three years in the plenum.
He does not believe this is a continuing release of resin. An investigation is being conducted.
'(Radiological Deficiency Report RDR 82-1-30-2)
Mr. Trudeau believes the spent resin, which was found on the 53 feet elevation, was drawn through the duct from the 23 feet elevation.
(feedwater demineralizer cubicles).
2.
An analysis of the spent resin will be performed as soon as it is feasible. We will be informed if any alpha activity or evidence of transuranics is found.
3.
The spent resin was bagged and drummed, but some was inadvertently scattered on the floor near the SBGTS.
The workers doing this work wore respirators, double gloves, plastic suits, and shoe covers.
(RWP No.82-273) Breathing zone air sampling indicated about 1.06 times the 10 CFR 20 Appendix B value was present.
B.
Pre-Existing RWP Not Updated On January 28, 1982, before the cleanup, a five man C.N. Flagg Construction Co. crew was doing electrical work on the SBGTS deluge system controls.
They wore street clothing, shoe covers, and gloves.
(RWP No. 82-43) The floor contamination level was 8,000 dpm/100 cm at that time and the general 2
area radiation level was two to 25 mrem /hr.
The SBGTS filter train was 1
posted as 200 mrem /hr on contact.
1 When starting work on January 29, 1982, this crew was briefed by a health physics technician who was unaware of any overnight changes in conditions.
The crew started work but the foreman stopped the job when he found his selfreader dosimeter indicated 10 mrem exposure.
- Originally stated to be 80 to 100 cubic feet - now stated to be 80 to 100 gallons.
4 63 g 3 860613 g,gg BURNSTEIS6-58 PDR
i File (DN 50-293) 2 The RWP was then terminated. Whole body counts of the five men indicated there were no uptakes of radioactive materials.
No greater than about a 10 mrem exposure to any individual was indicated.
The foreman of the above crew subsequently terminated (refused to continue j
work at Pilgrim).
His name is Clayton Lewis.
C.
Information Flow Mr. Trudeau stated that three different contract health physics technicians were involved in these events.
The initial discovery of spent resins on January 28, 1982, was not passed on to the technician responsible for the SBGTS area on January 29, 1982.
The technician working on the cleanup on the evening of January 28, 1982, logged the event in an ALARA logbook.
This was not passed on to the day crew responsible for RWPs on January 29, 1982, before work resumed.
4 Apparently no daily survey was made of the SBGTS area before allowing work j
to resume on January 29, 1982, under RWP No. 82-43.
I f
j D.
Corrective Action to Prevent Recurrence Mr. Trudeau stated that all known changes in conditions are now being j
brought to his attention in a timely manner.
)
l E.
Possible Enforcement Action Enforcement action may be appropriate in the following areas:
1.
Failure to label drums of spent resins.
2.
Failure to post the radiation areas at these drums and update the survey records.
3.
Failure to inform the workers of the precautions necessary in the area of the SBGTS on January 29, 1982.
4.
Procedural inadequacies ar failure to adhere to procedures.
These items appear appropriate for followup on a routine inspection.
In i
addition the licensee's investigation should be reviewed for adequacy.
a K. E. Plumlee i
Radiation Specialist i
CC.
/
i J. Johnson, Sr. Resident Inspector, Pilgrim V J. Joyner
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R ECOR D CATEGORY:
Smith T@_
W. J. Armstnong Prepared by _ R. A.
P. D. Smith Date _ March 2. MJ Reviewed by 1)T PNPS FILE NUMBER:
Iue.., n Approved by _
D. Smit Tcn R2-73
.r
Title:
BEAD RESIN IN STANDBY GAS TREATMENT SYSTEM bead resin found in the standby gas treatment system recently (giving b-f'
{ej t ' Rad Deficiency Report #82-1-30-2) is not something new.
This I
on has existed for almost as long as this station has been operating.
tu s
.)
I f It's root cause lies in problems associated with the condensate demineralizers f
([ventingsystem.
I All seven condensate demineralizer are connected to a 2" common vent l
v header with isolation from the header provided by an air operated valve x
l in each case.
The 2" vent header in turn ties into a 2h" vent header f"
from the cation, anion, and storage tanks, which in turn connects to a gas scrubber, the discharge of which goes into the reactor building A>
)
7 contaminated exhaust system in the area of the tip room on Rx. Bldg.
Attachment A is a simplified sketch of the above described i(gl. 23'.
tenting system.
ltThe condensate demineralizers' venting system provides the pathway to the
/
ventilation ductwork in the reactor building, but the manner by which resin from the condensate dcmineralizer has progressed this pathway is somewhat complicated and involves a series of heretofore unremedied I y'
)p,, problems.
The most realistic sequence of events appears to be as follows:
.II As the result of numerous occasions when the 2" vent header ruptured from overpressurization, it had been suspected for years that at least one, if not more, A0-4 valve was leaking through when it was supposed to be closed while its respective demineralizer was in service.
The vent header problem was alleviated through a PDCR which installed a motor operated valve and " drain line which was always kept open to keep the header from being overpressurized.
When all the 0-4 va Se'rt were_igspec_ted during this outage, it was discovered that six out of seven were defectR e and could not seal when closed! This means that in any operation where resin was being moved into any of the six demineralizers with the defective vent valves, the potential existed for having resin pass through a leaking vent valve (which
(
was supposed to be closed) and into the vent header-see Attachment B.
After the resin has been sluiced into a demineralizer, the next step is to fill the demineralizer with water while venting the air out of the tank. The designed method for this step is to continue filling the tank with water until the water floods up the tank vent line and into the vent header to a point prior to the header block valve where a sensing elenent is supposed to be located which is supposed to send a signal back to tae control panel for the operator to terminate the process - see Attachmett C.
It_is at this point that._pnpther_prphlp.gtcomes into play.
The sensinf, e
r Qnstrumentationhasneverworkedproperly)
Since the vent block valve is a*
C.- M esca. roem sass
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OFFICE MEMORANDUM
,,,4* Edison c..,
r, RECORO CATEGOR Y:
To-Prepared by UNIT APPLICA8ILITY:
Date Reviewed by CC:
PNPS FILE NUMBER:
TCH 82-73 Nudear Records Center Approved by
Title:
open during this step to allow the vented air to go to the gas scrubber and subacquently to the contaminated exhaust system, this means that the water could flood the header all the way up to and into the gas scrubber; not only could, but did - all the time!
Since the gas scrubber had a level indicator which could be observed by the operator, and since the designed " FULL" indication was not working, he would watch this indicator, and at the first sign of increasing level he would terminate the process.
Wo more problems enter here.
Once the gas scrubber starts to fill with water, it fills pretty fast!
Unfortunately the level indicator is in another room from the one containing the control panel which means the operator has to rush back to the control panel to throw the switch which terminates the filling c
process.
By design, the gas scrubber has an automatic 1 ump valvy which works off of a switch on the level indicator which is supposed to open and drain tne scrubber when the water level reaches a prescribed limit.
There are a number of problems associated with this dump valve operation, not the least of which is its complete failure to operate on numerous occasions.
When this valve fails to open, the water continues filling the scrubber and floods right up to and into the ventilation ductwork on El. 23' of the reactor butiding carrying any resin that may have been residing in the venting system due to the leaking vent valves described earlier.
Since the reactor building contaminated exhaust ties into the standby gas treatment system, it is very easy to get resin into that system any time it is operated, once the water in the ventilation ductwork dries up.
To the best of our knowledge, no new inventory of resin has been deposited in the ductwork since at least the implementation of the vent header drain line which was approximately a year and a half to two years ago.
All of the resin still showing up in the standby ga,s treatment system is from the residual deposited in the ductwork from earlier years.
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DCS No.
50293-820611 i
Dato:
June 11, 1982 PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE--PNO-1-82-42 This preliminary notification constitutes EARLY notice of events of POSSIBLE safety or 1
public interest significance. The information is as initially received without verift-l cotton or evaluation and is basically all that is known by.the Region I staff on this detec j
P11gria Nuclear Power Station i
Fecility:
Plymouth, Massachusetts Licensee Emergency Classification:
ON 50-293 Notification of Unusual Event 1
Alert l
Site Area Emergerxy l
_ General Emergency l
Not Applicable 3
Subject:
RELEASE OF SPENT RESIN j
At approximately 1300 on June 11, 1982 spent resin was found on the ground near the l
Turtine Building.
Subsequent surveys identified contamination of the roofs of the Turbine Reactor Off-Gas and Re-Tube Buildings.
Contamination was also found on the l
ground within the site controlled armas.
Contamination levels ranged from 20-30,000 dpm/100 cme with maxinun contamination of up to 100,000 dpe/100 ca.
Gasus isotopic c
analysis of the resin identified primarily long lived radionuclides (Co-60, Cs-137, 1
Cs-134 and Ri-54).
i No contamination was identified off-site or in stors drains.
All personnel art being l
frisked prior to exiting the site and no personnel contamination has been identified.
l.
The resin aey have been released themugh the reactor building vent duct which exhausts approximately 10 ftg an elevation of approximately 100 ft.
to the atnosphere a The licensee has found i
of resin in the Staney Gas Treatment System inlet plenum.
The l
source of the resin is being investigated.
Three radiation specialists have been j
dispatched to the site to evaluate the radiological aspects of the occurrence.
Media interest is expected due to pihlic interest in the facility. The licensee is i
considerinii issuing a press release.
The NRC does not plan to issue a press release but will respond to media inquiries.
The Connonwealth of Massachusetts has been inforned.
4 l
This PN is current as of 4:45 P.M., June 11, 1982.
CONTACT:
Elsasser Brunner 1
488-1235 488-1225 i
DISTRIBUTION:
H. St.
MNBB Phill1ps E/W Willste Mail: ADM:DMB i
Chairman Palladino EDO NRR IE NMSS DOT:Trans. Onig
{? Conn. Gilinsky.
- Conn. Ahearne MPA AE00 i ! Comm. Roberts ELD i. ACR$
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' PDR Regicnal Offices TMI Resident section RI Resident Office Licensee:
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(Reactor Licensees)
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Regien I Form 83
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Dau: June 14, 1982
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PRELIMINARY ISTIf:ICATI(310F EVENT OR UNUSUAL OCCURABICE--P i
This preliminary notification constitutes EARLY notice of events of POS public interest significance.CGtion or evaluation, and is basically all that is known by th this data.
Pilgrim nuclear Power Station Licensee Emergency Classification:
Fccility: Plymouth, Massachusetts Notification of Unusual Event DN 50-293 Alert Site Area Emergency General Emergency x
Not Applicable RELEASE OF SPENT RESIN (UPDATE PN0-I-82-42)
Suhject:
Surv2ys of the entire site within the protected area and surveys of selected areas of the licsnsee controlled area were made within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of the identification of the spent resin The licensee's onsite surveys identified to contaminated pavement areas which were barricaded and posted. Surveys confinned contamination of the Turbine, Administration, relsase.
The Reactor Building Roof was found to be Augmented Off-Gas and Re-Tube Building roofs.The licensee's offsite survey included surv free of contamination.
No contamination was identified. Routine lots, shorefront, and security access areas.
1-15, 1982 were counted.
Nothing cnvironmental air samles covering the oeriod June Because of the size and weight of the resins, no offsite airborne unusual was identified.
release of the beads appears to have occurred.
This was confinned by air samples collected during clean-up of the contaminated pavement areas which when counted indicated backgm Prelimin-and the identification of resins only on roof-tops under the Reactor Buiding Vent.
ary samples of stona drain residue have been counted with no contamination identified.
A duct surveillance program All contaminated ventilation ducts have been vacuumed clean.
has been established to identify any additional resin accunulation.
The licensee believes the resin entered the ventilation ducts frun the condensate dom In addition, alizer system during resin backwashing via the Cation Regeneration Tank Vent.
resin from defective condensate demineralizer vent valves may have also been released The resin pricr to their repair during the September 1981 -March 1982 refueling outage.
app;ars to have been released from the Reactor Building Ventilation Exhaust System which vsnts above the reactor building roof, prior to the repair of defective filters in this system in September 1981.
The licensee has suspended all transfer operations which could result in further resin The relcases to ventilation ducts and has initiated additional environmental sampling.
licensee's actions were monitorud by three Region ! Radiation Specialists throughout the Region I will issue a Confimatory Action Letter to address planned licensee we:kend.
The licensee is continuing to rvview the source and cause to detemine ccrrective actions.
what pennenent corrective action will be needed.
The Resident Inspectors are closely following licensee actions concerning this event.
Media interest has occurred. The licensee has responded to media inouiries but does not plan to issue a press release. The NRC will mspond to media inouiries but does not plan to issue a press release.
This PN is current as of 11:00 a.m.,, June 14, 1982.
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PNO-1-82-42A CONTACT: Nimitz Elsasser Starostecki 488-1329 488-1235 488-1229 DISTRIBUTION:
H. St.
MNBB Phillips E/W W111ste
_ Mail: ADM:0MB Chalmen Palladino EDO NRR 1E NMSS 00T:Trans. Only Commi. Gilinsky PA DIA RES Cossi. Ahearne MPA AE00 Comm. Roberts ELD ACRS Air Rights INPO SECY SP NSAC CA TMI Resident Section PDR Regional Offices RI Resident Office Licensee:
(Reactor Licensees)
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