ML081550645

Slides, Presentation to the NRC on the Causes and Corrective Actions of the Areva Np Mount Athos Road Shipment of Fuel Cleaning Equipment to the Watts Bar Plant Exceeding Transportation Radiation Limits.

ML081550645
Person / Time
Site:	Watts Bar, 07001201
Issue date:	05/28/2008
From:	Dunn V, Grandemange D, Land R, Geoffrey Wertz AREVA, AREVA NP
To:	NRC/RGN-II
References
Download: ML081550645 (17)

Text

> AREVA - NRC meeting. Atlanta May 28, 2008 1 Presentation to the NRC On the Causes and Corrective Actions of the AREVA NP Mount Athos Road Shipment of Fuel Cleaning Equipment to the Watts Bar Plant Exceeding Transportation Radiation Limits Ron Land VP Manufacturing Operations Dominique Grandemange Plant Manager Valerio Dunn Fuel Services Project Manager Geoffrey Wertz EHS&L Manager AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 2

Presentation Agenda

> Background

> Fuel Cleaning Equipment Overview

> Timeline / Risk Assessment

> Causal Analysis/Corrective Actions

> Conclusions AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 3

Background

On February 4, 2008, WB received a shipment of fuel cleaning equipment sent from the AREVA NP Inc, Mount Athos Road (MAR) facility. The receipt radiation survey indicated that Box 455 had a localized hot spot which exceeded the transportation requirements of 10 CFR 71.47.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 4

Fuel Cleaning Equipment Overview Purpose/Use:

• Ultrasonic cleaning system Primary Underwater used to remove material Components:

deposits from the fuel Filtration Unit cladding to reduce Axial Offset Anomaly improving thermal Ultrasonic Transducer performance Housing for Two Fuel Assemblies

• Secondary benefit to reduce plant source term - dose reduction System Design Considerations:

• Underwater components electro polished to support decontamination due to potential contamination

• Specific container design incorporates shipping restraints and shielding of anticipated high dose Fuel Cleaner Filtration Unit components Fuel Cleaner Fuel Assembly Ultrasonic Transducer Housing AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 5

Activity Timeline Pre-Shipment 12/13/07 Inappropriate Action - 2 MAR equipment surv ey performed.

Containment of high activity Filter Housing (FH) - 450 mr/hr on material not sufficient for contact. transport.

Pump - 7 R/hr - replaced.

Pre-operational checkout - 12 hrs of Inappropriate Action - 3 operation (flushing) prior to package for Equipment shipped on a flatbed shipment to WB. No change in trailer.

radiation lev els (fixed).

Inappropriate Action - 4 Lessons learned from past events not applied.

Nov-07 Dec-07 Jan-08 Feb-08 10/24/07 Equipment shipped from 1/31/08 Palisades. Pre-shipment surv ey:

Highest contact reading on FH remained 450 mr/hr Box 455 was 80 mr/hr.

10/26/08 Highest contact reading on MAR receipt surv ey 80 mr/hr. Box 455 was 40mr/hr.

> AREVA - NRC meeting. Atlanta May 28, 2008 6

Activity Timeline Post-Shipment 2/4/08 WB received shipment w ith Box 455: hot spot reading 2000 mr/hr, 150 mr/hr at 4 inches below box 2/9/08 (top of trailer bed), and 5-7 mr/hr beneath trailer.

Source material located Discussed shipment w ith WB staff - equipment w as in Box 455 and removed being handled safely using duct tape.

Box 455 returned to 1-2 Review ed shipment itinerary from trucking company mr/hr.

Performed risk review and concluded no immediate risk to driver, public nor w orkers.

WB unloaded the Box 455. Inappropriate Action - 5 No formal HP training on DRP.

Jan-08 Feb-08 Mar-08 Apr-08 Inappropriate Action - 1 2/6-9/08 2/19/08 Waited to send HP to WB MAR RP Source material returned to MAR.

Tech to WB Reading 800 mr/hr behind 3/16" plate, 14 mr/hr to perform at 1', and 2 mr/hr at 36".

survey Isotopic Analysis -long-lived corrosion readings. products.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 7

Summary of Survey Results MAR Survey Data WB Survey Data OUTSIDE of box 455 Detector : TELEPOLE Detector : TELETECTOR (gamma readings) 800 mr/hr on contact 2000 mr/hr gamma and beta on contact 25 mr/hr at 12 inches 150 mr/hr at 4 inches Performed at WB No smearable contamination No smearable contamination INSIDE of box 455 Detector : TELEPOLE Detector : RSO-5 800 mr/hr on contact 1500 mr/hr on contact (open window)

Performed at WB 70 mr/hr at 12 inches 800 mr/hr on contact (closed window)

INSIDE of BOX 455 after removal Detector : TELEPOLE of "Hot Spot" Performed at WB 1 to 2 mr/hr on contact On hot spot removed Detector : TELEPOLE from BOX 455 Performed at MAR 1100 mr/hr on contact On hot spot removed Detector : TELEPOLE from BOX 455 with 3/16" plate 800 mr/hr on contact Performed at MAR 14 mr/hr at 12 inches Good Gamma Survey Data Consistency With No External Beta Contamination Found AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 8

Safety Significance Survey data illustrated graphically Conclusion of Risk Assessment :

No Undue Risk to the Public or Truck Driver AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 9

Causal Analysis & Corrective Actions

> Two Apparent Causes AC #1 - The procedure for pre-shipment surveys did not have an activity threshold for additional consideration of containment of high activity material prior to transport.

AC #2 - The procedure for pre-shipment surveys did not have any specific requirements for consideration of additional packaging or use of a closed conveyance trailer.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 10

Causal Analysis & Corrective Actions

> Corrective Action #1 Established pre-shipment radiation survey activity thresholds.

• Thresholds trigger additional management review

• Applicable to all MAR equipment shipments.

> Corrective Action #2 Clarified roles and responsibilities for RP and operations personnel to ensure proper packaging of all radioactive equipment.

• Enhanced ownership of equipment packaging.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 11

Causal Analysis & Corrective Actions

> Corrective Action #3 Added requirement to perform extensive surveys of highly contaminated equipment, for example:

• Reactor Cavity

• Below the Reactor Head

• Spent Fuel Pool

> Corrective Action #4 Fuel Cleaning Equipment is transported in a closed conveyance.

> Above requirements added to SL-1600, Shipment and Receipt of Radioactive Material.

> CAs 1 - 4 are completed AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 12

Contributing Causes & Corrective Actions

> CC #1 - Extent of Condition Review had not been performed using previous MAR receipt shipments which exceeded transportation limits.

> Corrective Action

1. 1 - Performed an external assessment of RP practices in shipment preparation - complete.

• Results matched internal ACA findings.

1. 2 - Open CA to perform a Lessons Learned Review.

• Implemented through CAP and audit process.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 13

Contributing Causes & Corrective Actions

> CC #2 - RP technicians did not have formal training on Discrete Radioactive Particles (DRP).

> Corrective Actions

1. 1 - Procedure SL-1291,Discrete Radioactive Particle Control created

1. 2 - RP technicians were trained on the procedure.

1. 3 - Formal DRP Training Program developed.

1. 4 - Initial & Recurring Training added to the RP annual curriculum.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 14

Contributing Causes & Corrective Actions

> CC #3 - There was a 2 day delay in dispatching a MAR RP technician to support the event investigation.

> Corrective Action Requirement to dispatch an RP technician immediately if a transportation container exceeds any transportation limit.

Requirement added to procedure SL - 1600.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 15

Corrective Action Summary

> Corrective Actions 1 - 4 are complete.

> Subsequent Lessons Learned Review will validate apparent and contributing causes and ensure effectiveness of CA implementation.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 16

Conclusions

> MAR recognizes the potential risk this event as important. In this case, the risk to the public or workers was very low.

> MAR causal analysis investigation was comprehensive.

> Corrective actions were comprehensive and complete.

AREVA NP Inc. > AREVA - NRC meeting. Atlanta May 28, 2008 17