ML21067A209
| ML21067A209 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/08/2015 |
| From: | ZionSolutions |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML21067A225 | List:
|
| References | |
| ZS-2021-0001 | |
| Download: ML21067A209 (5) | |
Text
Event Details - Condition Report Condition Report - CR-2015-000324 Attributes Properties Number CR-2015-000324 Class eB CA\\Incident Forms\\Condition Report Name CONTAMINATION IDENTIFIED ON THE GROUND O Description A TEMPORARY RADIOACTIVE MATERIAL AREA WAS CREATED ON THE NORTH SIDE OF UNIT 2 CNMT TO CONTAIN SEVERAL SEGMENTED PIECES OF UNIT 2 STEAM GENERATOR SECONDARY SIDE COMPONENTS. THIS MATERIAL WAS LOADED INTO RAIL CARS FOR SHIPMENT ON 06/02/2015 AND 06/03/2015.
StartDate 6/4/2015 11:08:41 AM EndDate 9/8/2015 Approval Status Approved Attribute Value Evaluation Due Date 7/28/2016 SIG Level SIG3 Assigned Evaluation None Evaluation Due Date 7/28/2016 Issue Review required?
Actions Required Date/Time Initiated 6/4/2015 Brief Description Contamination Identified on the Ground on the North Side of Unit 2 CNMT Detailed Description A temporary radioactive material area was created on the North side of Unit 2 CNMT to contain several segmented pieces of Unit 2 Steam Generator secondary side components. This material was loaded into rail cars for shipment on 06/02/2015 and 06/03/2015. Once completed, the area was surveyed by RP Ops personnel. No contamination was identified and the area was downposted. This downposting occurred around 1600 on 06/03/2015. This was in violation of procedure ZS-RP-106-000-000 "Radioactive Material Control Program" procedure as FSS personnel are required to evaluate the area prior to deposting. FSS personnel were contacted previously, and, when arriving to survey, found the area already downposted. RP Operations personnel were contacted and the area was reposted. The area was not posted for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
During surveys by FSS, several areas of contamination were identified. RP Management personnel were immediately contacted who then contacted the Control Room. D&D work was stopped in both CNMTs and all RPTs were redirected outside to the area to resurvey. Some additional locations were identified. 24 locations were identified in all, highest was 500k dpm, lowest was 20k dpm and average was around 50k dpm. All areas were remediated. After obtaining concurrence with FSS/LTP Manager in the morning on 06/04/2015, the area was then downposted. The survey instruments RP Operations uses are gm tube detectors which primarily identify beta emissions from contamination. FSS uses sodium iodide detectors which identify gamma emissions from contamination. The contamination identified and remediated was near surface to several inches below surface. This results in most or all beta emissions being shielded and not able to be located with gm detectors as the primary radionuclide present in the contamination is Co-60. This is the primary reason no contamination was identified by RP Ops during earlier surveys. NaI detectors were loaned to RP Ops to perform subsequent surveys for identification and remediation of contamination in the evening of 06/03/2015.
Immediate Actions Contacted Control Room to screen for reportability. The highest contamination identified was 500k dpm. For reportability screening, a bounding assumption of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of skin contact was assumed which could have resulted in worst case 2 rem of skin dose. That level would not have violated any site administrative or regulatory limits. That level of SDE would not be deemed feasible due to contamination being subsurface, the time the area was down-posted was approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and all personnel exiting site pass through the PM-7s which would have identified the contamination. Therefore, the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was for bounding purposes only.
Briefed all RPSs and RPTs on FSS evaluation requirements for downposting RMAs on 06/04/2015 during weekly safety brief.
Events Recommended Actions The contamination levels on the S/G secondary side pieces previously located in the area were less than 10k dpm/100cm2 removeable and fixed. The contamination identifed on the ground is not believed to have originated from that RAM. Therefore, the improper temporary down-posting of the area cannot be directly tied the consequences of identifying the radioactive material that existed prior to initially posting the area. The contamination was primarily Co-60 in nature and would have originated from primary side components in Unit 2 CNMT. The date and exact cause for spread of contamination cannot be determined. This area and the similar area on the south side of Unit 1 CNMT are known to have low levels of contamination from earlier FSS surveys. Recommended action is to have FSS perform NaI walk over surveys of laydown areas outside Unit 1 and Unit 2 CNMTs, as radiological background conditions allow, to identify and remediate any discrete radioactive particles and contamination identified at levels based upon concurrence of Director of Radiation Protection and FSS/LTP Manager.
Date Discovered 6/3/2015 Issue Identified By Initiator Related Documents The completion of the CR and its associated CAs was acceptable. RAF 09/08/15 Date/Time Reviewed 6/4/2015 Maintenance Rule Applicable?
No Reportability Applicable?
No Operability Review Required?
No Immediate Actions Taken?
No Work Request Initiated?
No 50.75G Issue Yes 7230D Issue No All Required CAs Complete?
Yes All Required Documentation Attached?
Yes CA Completion Appears To Satisfy CR Intent Yes Event Date 6/3/2015 Message
- Have Cause Codes been assigned to CR? - Have Event Codes been assigned to CR? - Have related Documents been linked to CR?
Scheduled Completion Date 11/24/2016 Stage Closed Trend Status Active Relationship Code Name Start Date End Date Approval Status Corrective Action CR-2015-000324-CA001 WORK WITH FSS TO PERFORM NAI WALK OVER S 6/8/2015 7/21/2015 Approved Corrective Action CR-2015-000324-CA002 PROCURE ADDITIONAL INSTRUMENTATION TO SU 6/8/2015 7/21/2015 Approved Corrective Action CR-2015-000324-CA003 REVISE NECESSARY PROCEDURES TO SUPPORT A 6/8/2015 9/8/2015 Approved
Responsibilities WorkOrders Trends Event Details - Corrective Actions Corrective Action - CR-2015-000324-CA001 Attributes 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 FAFLAMMINI Flammini, Frank Number Name Class Status CR-2015-000324 CR-2015-000324 Condition Report Completed Code Description Person Start Date End Date INITIATION CR Initiation Chris RC Keene 6/4/2015 6/4/2015 OP REVIEW Operations Review Frank FA Flammini 6/4/2015 6/4/2015 SCREENING CR Screening Roger R Flahive 6/8/2015 6/8/2015 SIG 3 Sig 3 - Owner Assignment Roger R Flahive 6/8/2015 6/8/2015 CAPTURE CA Capture Apprd Cas Roger R Flahive 6/8/2015 6/8/2015 PEND CA COMPLETION Pend CA Completion Roger R Flahive 9/8/2015 9/8/2015 VERIFY AND CLOSURE Verify & Closure Roger R Flahive 9/8/2015 9/8/2015 Group Code Group Name Code Name CC-0001 Cause Codes A7-B2-C01 Legacy contamination EC-0001 Event Codes 03E Radiation Protection - Equipment or area contamination event Properties Number CR-2015-000324-CA001 Class eB CA\\CAP Actions\\Corrective Actions Name WORK WITH FSS TO PERFORM NAI WALK OVER S StartDate 6/8/2015 EndDate 7/21/2015 Approval Status Approved Scope Global Attribute Value CA Due Date 8/6/2015 CA Description Work with FSS to perform NaI walk over surveys of laydown areas outside Unit 1 and Unit 2 CNMTs, as radiological background conditions allow, to identify and remediate any discrete radioactive particles and contamination identified at levels based upon concurrence of Director of Radiation Protection and FSS/LTP Manager.
CA Owner Comments Surveys are complete of ground areas outside Unit 1 and Unit 2 CNMTs. Surveys are on file with FSS group. A total of 75 areas were identified and remediated which contained varying levels of discrete radioactive particles and distributed contamination.
Stage Closed
WorkOrders Corrective Action - CR-2015-000324-CA002 Attributes WorkOrders Corrective Action - CR-2015-000324-CA003 Number Name Class Status CR-2015-000324-CA001 CR-2015-000324-CA001 Corrective Actions Completed Code Description Person Start Date End Date ASSIGN OWNER CA Owner Assignment Roger R Flahive 6/8/2015 6/8/2015 COMPLETE CA CA Completion Chris RC Keene 7/16/2015 7/16/2015 REVIEW CA CA Review Roger R Flahive 7/21/2015 7/21/2015 Properties Number CR-2015-000324-CA002 Class eB CA\\CAP Actions\\Corrective Actions Name PROCURE ADDITIONAL INSTRUMENTATION TO SU StartDate 6/8/2015 EndDate 7/21/2015 Approval Status Approved Scope Global Attribute Value CA Due Date 8/6/2015 CA Description Procure additional instrumentation to support this CR's resolution and prevention of future events.
CA Owner Comments A review of FSS/LTP work and instrumentation was performed and no additional instrumentation is required to be procured. An adequate supply of instrumentation is available at the site.
Stage Closed Number Name Class Status CR-2015-000324-CA002 CR-2015-000324-CA002 Corrective Actions Completed Code Description Person Start Date End Date ASSIGN OWNER CA Owner Assignment Roger R Flahive 6/8/2015 6/8/2015 COMPLETE CA CA Completion Chris RC Keene 7/16/2015 7/16/2015 REVIEW CA CA Review Roger R Flahive 7/21/2015 7/21/2015 Properties Number CR-2015-000324-CA003 Class eB CA\\CAP Actions\\Corrective Actions Name REVISE NECESSARY PROCEDURES TO SUPPORT A StartDate 6/8/2015 EndDate 9/8/2015 Approval Status Approved Scope Global
Attributes WorkOrders Attribute Value CA Due Date 9/10/2015 CA Description Revise necessary procedures to support any process changes.
CA Owner Comments A review of procedures and processes were performed and no procedure changes were deemed necessary. RP Operations personnel whom have been trained on more sensitive instrumentation are being utilized to survey and down post radioactive material areas when needed. The use of the more sensitive instrumentation so far has been beneficial as some contamination has been identified by RP Ops before FSS RP personnel have performed their follow-up surveys.
Stage Closed Number Name Class Status CR-2015-000324-CA003 CR-2015-000324-CA003 Corrective Actions Completed Code Description Person Start Date End Date ASSIGN OWNER CA Owner Assignment Roger R Flahive 6/8/2015 6/8/2015 COMPLETE CA CA Completion Chris RC Keene 9/3/2015 9/3/2015 REVIEW CA CA Review Roger R Flahive 9/8/2015 9/8/2015