ML21067A191
| ML21067A191 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 11/13/2014 |
| From: | ZionSolutions |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21067A225 | List:
|
| References | |
| ZS-2021-0001 | |
| Download: ML21067A191 (4) | |
Text
Event Details - Condition Report Condition Report - CR-2014-001074 Properties Number CR-2014-001074 Class eB CA\Incident Forms\Condition Report Name CONTAMINATION IDENTIFIED ON THE GROUND I ON 09/24/2014, AN 8-120 LINER WAS LOADED INTO AN 8-120B SHIPPING CASK IN THE SOUTH YARD. THE LINER Description WAS REMOVED FROM ONE OF THE RAD VAULTS WITHIN THE STORAGE ARRAY. THE FOLLOWING IS A BASIC SEQUENCE OF EVENTS THAT TYPICALLY OCCUR: THE RAD VAULT LID IS StartDate 9/25/2014 10:24:23 AM EndDate 11/13/2014 Approval Approved Status Attributes Attribute Value Evaluation Due 3/20/2015 Date Evaluation/Review 11/12/2014 Sent To CR Owner Evaluator Evaluator comments as well as the Department Head, CAP Organization, and HU comments were Comments incorporated into the ACE prior to MRC review and approval. RAF 11/13/14 SIG Level SIG2 Assigned ACE Evaluation Evaluation Due 3/20/2015 Date Date/Time 9/25/2014 Initiated Brief Description Contamination Identified on the ground in South Array During Waste Shipment On 09/24/2014, an 8-120 liner was loaded into an 8-120B Shipping Cask in the South Yard. The liner was removed from one of the rad vaults within the storage array. The following is a basic sequence of events that typically occur: The Rad vault lid is removed and liner is disengaged from the overpack. The liner is withdrawn into the T-Bell. The bottom of the liner is perforated to allow water to drain out when removing from the Reactor Cavity; therefore, there is a high potential for loose contamination on the bottom of the liner that is no longer covered. At this point the T-Bell/liner is moved over the north side of the array and set down upon herculite or similar covering the asphalt. The overpack in the rad vault is inspected for residual water. If water is identified, it is removed and controlled. The overpack is then picked up and moved over to the north side of the array. A secondary enclosure (bag) is placed around the overpack and secured then the overpack/bag is placed inside of the shipping cask which is on the truck trailer. The T-Bell/liner is then moved over the top of the shipping cask and the liner is lowered into the overpack/bag until fully engaged. The T-Bell is then set back on the herculite. The secondary enclosure (bag) is sealed around the liner/overpack within the shipping cask. The placement of the secondary enclosure is required by the 8-120B shipping cask Certificate of Compliance. Mock-ups were performed last year with empty liner/overpack combinations as an ALARA tool. Placement of the bag around the liner/overpack when together is not feasible due to relatively high contact dose rates exceeding 100 R/hr. Placement of the bag inside the shipping cask then lowering the liner/overpack into the bag was also not feasible due to the amount of time spent controlling the bag during lowering and the high contact dose rates. This process also Detailed resulted in ripping the bag. Newer bags are currently being used that are looser fitting reducing the risk of Description tearing if that method was used. However, the risk of tearing still exists and would not be realized until the package reaches its destination. Therefore, that method is still not deemed feasible due to risk of secondary closure failure and inability to verify integrity. The most ALARA method was to disengage the liner from the overpack and place the bag around the overpack then place the overpack into the shipping cask. This allows personnel to take their time with the secondary enclosure and not accumulate additional dose. It does require some additional dose to disengage the liner from the overpack but this dose is a small fraction of what would be accumulated using other methods. A covering on the bottom of the T-Bell could be used for both movements, but this was deemed not ALARA due to the dose taken to install and remove the covering.
Also, the risk of spread of contamination during removal of the covering exceeds the risk of spread of contamination during movement of the liner uncovered. RP and Waste Operations are aware of the potential for any loose material to fall from the liner during the two moves. RP controls the area, monitors personnel and surveys the travel path, as well as, adjacent areas outside the travel path. The condition identified in this CR was known, was briefed and was handled appropriately. EN-ZN-407 was entered for release of radioactive material to the soil in the South Yard near the rad vault array. Control room was notified. There were multiple slivers/chips identified on the ground in the travel path of the liner between the rad vault and the shipping cask. Slivers/particles were in the range of 50k dpm to 7 million dpm. RP identified the material via routine survey at the end of evolution. All material was collected and returned into the main RCA. The travel path was resurveyed as well as adjacent areas after cleanup and area was cleared. There was one PCE of 30k dpm on an individu Immediate Actions Surveyed area, identified and remediated RAM.
Recommended Close to Actions Taken.
Actions Date Discovered 9/24/2014 Issue Identified By Initiator Related The completion of the CR and its associated CA was acceptable. RAF 11/13/14 Documents Date/Time 9/25/2014 Reviewed Maintenance Rule No Applicable?
Reportability No Applicable?
Operability Review No Required?
Immediate Actions Yes Taken?
When notified of the issue on 9/24/14, entered EN-ZN-407, Response To Inadvertent Releases Of Licensed Immediate Actions Materials To Groundwater, Surface Water Or Soil and ZAP-110-07, Significant Event Reporting. Performed Description reportability review per LS-AA-1120 and LS-MW-1320 based on information provided by RP and determined as non-reportable.
Work Request No Initiated?
50.75G Issue Yes 7230D Issue No MRC Review 11/12/2014 Meeting Date MRC Approval Yes The ACE was reviewed and approved by the MRC on 11/12/14. See the attached file under CA001. There MRC Comments were three MRC comments regarding the ACE; 1) Correct typos and grammar, 2) Add Event Code, and 3)
Add completed Planned Action 3. There were no open actions to enter into eB Nuclear. RAF 11/13/14 All Required CAs Yes Complete?
All Required Documentation Yes Attached?
CA Completion Appears To Satisfy Yes CR Intent Event Date 9/24/2014
- Have Cause Codes been assigned to CR? - Have Event Codes been assigned to CR? - Have related Message Documents been linked to CR?
Scheduled 3/23/2015 Completion Date Stage Closed Trend Status Active
Events Relationship Code Name Start Date End Date Approval Status Corrective CR-2014- CONDUCT ACE - CONTAMINATION 9/29/2014 11/13/2014 Approved Action 001074-CA001 IDENTIFIED O Condition CONTAMINATION IDENTIFIED ON CR-2014-001074 9/25/2014 11/13/2014 Approved Report THE GROUND I Condition CONTAMINATION IDENTIFIED ON CR-2014-001074 9/25/2014 11/13/2014 Approved Report THE GROUND I Responsibilities ResponsibilityType Organization Code Organization Name Person Code Person Name CR Owner DCSF DCS Fuel RAFLAHIVE Flahive, Roger Initiator RP ESH - Radiation Protection RCKEENE Keene, Chris Shift Manager EXLN Exelon MARK.BITTMANN Bittmann, Mark WorkOrders Number Name Class Status CR-2014-001074 CR-2014-001074 Condition Report Completed Code Description Person Start Date End Date INITIATION CR Initiation Chris RC Keene 9/25/2014 9/25/2014 OP REVIEW Operations Review Mark MJ Bittmann 9/25/2014 9/25/2014 SCREENING CR Screening Roxanne RXH Hendrickson 9/29/2014 9/29/2014 SIG 2 Sig 2 - Owner Assignment Roxanne RXH Hendrickson 9/29/2014 9/29/2014 CAUSE EVALUATION Cause Evaluation Roger R Flahive 9/29/2014 11/13/2014 MRC REVIEW MRC Review Roger R Flahive 11/13/2014 11/13/2014 CAPTURE CA Capture Apprd Cas Roger R Flahive 11/13/2014 11/13/2014 PEND CA COMPLETION Pend CA Completion Roger R Flahive 11/13/2014 11/13/2014 VERIFY AND CLOSURE Verify & Closure Roger R Flahive 11/13/2014 11/13/2014 Trends Group Group Code Name Code Name C C -0001 Cause Codes A3-B2-C04 Previous success in use of rule reinforced continued use of rule EC-0001 Event Codes 03E Radiation Protection - Equipment or area contamination event Event Details - Corrective Actions Corrective Action - CR-2014-001074-CA001 Properties Number CR-2014-001074-CA001 Class eB CA\CAP Actions\Corrective Actions Name CONDUCT ACE - CONTAMINATION IDENTIFIED O StartDate 9/29/2014 EndDate 11/13/2014 Approval Status Approved Scope Global
Attributes Attribute Value CA Due Date 11/3/2014 Conduct ACE - Contamination Identified on the ground in South Array During Waste Shipment CR-2014-CA Description 001084 and CR 2014-001090 have been closed to this ACE.
CA Owner See the attached supporting file for the FINAL ACE that was reviewed and approved by MRC on 11/12/14.
Comments RAF 11/12/14 Stage Closed WorkOrders Number Name Class Status CR-2014-001074-CA001 CR-2014-001074-CA001 Corrective Actions Completed Code Description Person Start Date End Date ASSIGN OWNER CA Owner Assignment Roxanne RXH Hendrickson 9/29/2014 9/29/2014 COMPLETE CA CA Completion Chris RC Keene 11/5/2014 11/5/2014 REVIEW CA CA Review Roger R Flahive 11/13/2014 11/13/2014 Files Document File TMP14-2279 ACE-2014-001074 Spread of Contamination - Post MRC FINAL.pdf TMP14-2279 Ariel Views.pdf