AEP-NRC-2008-44, Submittal of Hazardous Materials Incident Report

Submittal of Hazardous Materials Incident Report

ML083020398
Person / Time
Site:	Cook
Issue date:	10/20/2008
From:	Weber L Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP-NRC-2008-44
Download: ML083020398 (9)

Text

Indiana Michigan Power Company INDIANA MICIGDANA Nuclear Generation Group One Cook Place MICHIGAN Bridgman, MI 49106 P*OVER aep.com October 20, 2008 AEP-NRC-2008-44 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk .

Mail Stop O-P1-17 Washington, DC,20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 SUBMITTAL OF HAZARDOUS MATERIALS INCIDENT REPORT In a letter dated October 9, 2008, Indiana Michigan Power Company,_ the licensee for Donald C. Cook Nuclear Plant (CNP) Units 1 and 2, submitted a Hazardous Materials Incident Report to the e)partmentoPf-TIransportaton (DoT).

On September 19, 2008, at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, the CNP Materials Center received a shipment of two area radiation monitors from ThermoFisher Scientific. There was no indication that each monitor contained any radioactive material because the "shipment confirmation" receipt stated that the radioactive sources were to be removed and shipped separately to CNP. The two units were-then transported to CNP for receipt by the requesting organization. After the units were delivered to CNP, it was determined that each area monitor contained a Strontium-90 check source in the amount of 0.33 pCi and 0.35 pCi, respectively (total 0.68 pCi).

The shipment was not marked in compliance with DOT regulation 173.422(a) (Marking appropriate UN number). The vendor was im mediately contacted to confirm each radioactive source amount since there.were.no markings on the packaging or documentation included with either-area monitor.

It was determined that the area. monitors should have been shippeld in :accordance with 49 CFR 173.424 as "Radioactive Material, Excepted Package - Instruments," and the box labeled UN2911.

In accordance with Section 5.4.2, of Part il, of Appendix B of the Environmental Technical Specifications for .CNP, a copy of the notification is included as an enclosure to this letter.

This letter contains no new commitments. Should you have any questions or concerns regarding this notification, please contact Jon H. Harner, Environmental Manager, at (269) 465-5901, extension 2102.

ly, WSince Lawrence J. Weber Site Vice President JEN/rdw Enclosure

U. S. Nuclear Regulatory Commission AEP-NRC-2008-44 Page 2 c: T.A. Beltz - NRC Washington DC J. L. Caldwell - NRC Region III K. D. Curry - AEP Ft. Wayne, w/o enclosure J. T. King - MPSC, w/o enclosure MDEQ - WHMD/RPS, w/o enclosure NRC Resident Inspector

ENCLOSURE TO AEP-NRC-2008-44 HAZARDOUS MATERIALS INCIDENT REPORT

Indiana Michigan Power Company Nuclear Generation Group INDIANA One Cook Place M101" Bridgman, MI 49106 aep.com October 9, 2008 AEP-DOT-2008-1 Information Systems Manager PHH-63 Pipeline and Hazardous Materials Safety Administration Department of Transportation Washington, DC 20590-0001

Subject:

Donald C. Cook Nuclear Plant Hazardous Materials Incident Report This notification of an "Undeclared Shipment with no Release" is being made pursuant to Department of Transportation (DOT) regulation 49 CFR 171.16(b)(1), which requires submittal of a Hazardous Materials Incident Report within 30 days of the identification of an event.

On September 19, 2008, at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, Donald C. Cook Nuclear Plant (CNP)

Materials Center received a shipment of two area radiation monitors from ThermoFisher Scientific.

There was no indication that each monitor contained any radioactive material because the "shipment confirmation" receipt stated that the radioactive sources were to be removed and shipped separately to CNP. The two units were then. transported to CNP for receipt by the requesting organization. After the units were delivered to CNP, it was determined that each area monitor.

contained a Strontium-90 check source in the amount of 0.33 pCi and 0.35 pCi, respectively (total 0.68 pCi).

The shipment was not marked in compliance with DOT regulation 173.422(a) (Marking appropriate UN number). The curie content limits and subsequent marking and packaging requirements for the area monitors were not met based on DOT regulatory guidance found in 49 CFR 173.436 (Exempt material activity concentrations and exempt consignment activity limits for radionuclides - Sr-90 limit of 0.27 pCi) and 49 CFR 173.424 (Excepted packages for radioactive instruments and articles).

The vendor was immediately contacted to confirm each radioactive source amount since there were no markings on the packaging or documentation included with either area monitor. It was determined that the area monitors should have been shipped in accordance with 49 CFR 173.424 as "Radioactive Material, Excepted Package - Instruments," and the box labeled UN291 1.

The sources were surveyed for radiation and loose contamination with the results being <0.2 mr/hr

.(radiation dose rate) and <1,000 dpm/1OOcm 2 beta-gamma and <20 dpm/1OOcm 2 alpha (contamination). The sources were removed from each monitor and placed under lock and key in an approved radioactive material storage area. There was no personnel injury or fatality, no cause for evacuation, no transportation arterial rerouting, crash, or derailment involved.

U. S. Department of Transportation AEP-DOT-2008-1 Page 2 Should you have any questions, please contact me at (269) 465-5901, extension 2102.

Sincerely, Jon H. Harner Environmental Manager SRH/JEN/rdw Enclosure

SU.S. Department of Transportation Hazardous Materials Form Approval OMB No. 2137-0039 Pipeline and Hazardous Materials Safety Adrinistration According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 2137-0039. The filling out of this information is mandatory and will take 96 minutes to complete.

INSTRUCTIONS: Submit this report to the Information Systems Manager, U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Office of Hazardous Materials Safety, DH M-63, Washington, D.C. 20590-0001. If space provided for any item is inadequate, use a seperate sheet of paper, identifying the entry number being completed, Copies of this form and instructions can be obtained from the Office of Hazardous Materials Website at http://hazmat.dot.gov. If you have any questions, you can contact the Hazardous Materials Information Center at 1-800-HMR-4922 (1-800-467-4922) or online at http://hazmat.dot.gov.

PART I - REPORT TYPE

1. This is to report: 0l A) A hazardous material incident 0 B) An undeclared shipment with no release El CIA specification cargo tank 1,000 gallons or greater containing any hazardous materials that (1) received structural damage to the lading retention system or damage that requires repair to a system intended to protect the lading retention system and (2) did not have a release.

2. Indicate whether this is: 0 An initial report El A supplemental Ifollow-up) report El Additional Pages PART II- GENERAL INCIDENT INFORMATION

3. Date of Incident: 09/19/2008 4. Time of Incident (use 24-hour time): 11:00

5. Enter National Response Center Report Number (if applicable): N/A

6. If you submitted a report to another Federal DOT agency, enter the agency and report number: N/A

7. Location of Incident: City: Bridgman County: Berrien State: MI ZIP Code (if known): 49106 Street Address/Mile Marker/Yardname/Airporf/Body of Water/River Mile

8. Mode of Transportation El Air 0 Highway El Rail El Water

9. Transportation-Phase El In Transit El Loading El Unloading El In Transit Storage

10. Carrier/Reporter Name Federal Express Street 5313 Majestic Pkwy City Bedford State ZIP Code Federal DOT ID Number Hazmat Registration Number

11. Shipper/Offeror Name ThermoFisher Scientific Street One Thermo Fisher Way City Oakwood Village State OH ZIP Code 44146 Waybill/Shipping Paper Hazmat Reaistration Number

12. Origin Stree it (if different from shipper address) City ' State ZIP Code

13. Destination Stree t City State ZIP Code

14. Proper Shipping Name of Hazardous Material: Radioactive.Material, Excepted Package - Instruments

15. Technical/Trade Name: Sr-90 Check Source in DA1-6CC

16. Hazardous Class/ 17. Identification 18. Packing 19. Quantity Division: 7 Number:. UN2911 Group: None Released: None (E.g. UN2764, NA 2020) (if applicable) (Include Measurement Units)

20. Was the material shipped as a hazardous waste? El Yes 0 No If yes, provide the EPAManifest Number:

21. Is this a Toxic by Inhalation (TIH) material? El Yes 0] No If yes, provide the Hazard Zone:

22. Was the material shipped under an Exemption, Approval, or Competent Authority Certificate? 0l Yes 0 No If yes, provide the Exemption, Approval, or CA number:

23. Was this an undeclared hazardous materials shipment? El Yes ElNo Form DOT F 5800.1 (01-2004) Page 1 Reproduction of this form is permitted

PART III - PACKAGING INFORMATION

24. Check Packaging Type (check only one - if more than one, list type of packaging, copy Part Ill, and complete for each type:

[] Non-bulk EDIBC [E Cargo tank Motor Vehicle (CTMV) 0l Tank Car

[] Cylinder [3 RAM 0l Portable Tank 0l Other

25. See instructions and enter the appropriate failure codes found at the end of the instructions. Be sure to enter the codes from the list that corresponds to the particular packaging type checked above. Enter the number of codes as appropriate to describe the incident.

Enter the most important failure point in line 1. If there are more than two failure points, provide in this format in part VI.

1. What Failed: How Failed: Causes of Failure: 5 1 5

2. What Failed: How Failed: Causes of Failure: 5 1 7 26a. Provide the packaging identification markings, if available.

Identification Markings: None - Marking only was required.

(Examples: 1A1/Y1;4/150/92/USA/RB/93/RL, UN31H11Y0493/USA/M9339/10800/1200, DOT - 105A - 100W (RAIL), DOT 406 (HIGHWAY), DOT 51, DOT 3-A) 26b. For Non-bulk, IBC, or non-specification packaging, if identification markings are incomplete or unavailable, see instructions and complete the following:

Single Package or Outer Packaging: Single Package or Inner Packaging (if any):

Packaging Type: Fiberboard Box Packaging Type:

Material of Construction: Fiberboard Material of Construction:

Head Type (Drums only): El Rei movable 0l rNon - Removable

27. Describe the package capacity and the quantity:

Single Package or Outer Packaging: Single Package or Inner Packaging (if any):

Package Capacity: N/A Package Capacity:

Amount in Package: Amount in Package:

Number in Shipment: Number in Shipment:

Number Failed: Number Failed:

28. Provide packaging construction and test information, as appropriate:

Manufacturer: N/A Manufacture Date:

Serial Number: Last Test Date:

Material of Construction: (ifTank Car, CTMV, Portable Tank, or Cylinder)

Design Pressure: (if Tank Car, CTMV, Portable*Tank)

Shell Thickness: (if Tank Car, CTMV, Portable Tank)

Head Thickness: (if Tank Car, CTMV)

Service Pressure: (if Cylinder)

If valve or device failed:

Type: Manufacturer: Model:

(if present and legible) (if present and legible)

29. If the packaging is for Radioactive Materials, complete the following:

Packaging Category: [E Type A El Type B El Type C [9 Excepted El Industrial Packaging Certification: 0l Self Certified El U.S. Certification Certification Number Nuclide(s) Present: Sr-90 Transport Index: N/A Activity: 0.68 uCi Critical Safety Index: N/A Form DOT F 5800.1 (01-2004) Page 2 Reproduction of this form is permitted

PART IV - CONSEQUENCES

30. Result of Incident (check all that apply): [I Spillage El Fire [I Explosion El Material Entered Waterway/Storm Sewer El Vapor (Gas) Dispersion El Environmental Damage [Z] No Release

31. Emergency Response : The following entities responded to the incident: Z(Check all that apply)

El Fire/EMS Report# __ Police Report# __ In-house cleanup El Other Cleanup

32. Damages: Was the total damage cost more than $500? 0 Yes 0 No If yes, enter the following information: If no, go to question 33.

Material Loss: Carrier Damage: Property Damage: Response Cost: Remediation/Cleanup Cost:

$ _ _ _ _ _$ _ _ _ _ $ _ _ $__ _ _ _ _ $ _ _ _ _ _

(See damage definitions in the instructions) 33a. Did the hazardous material cause or contribute to a human fatality? El Yes El No If yes, enter the number of fatalities resulting from the hazardous material:

Fatalities: Employees Responders General Public 33b. Were there human fatalities that did not result from the hazardous material? El Yes- 0l No If yes, how many? __

34. Did the hazardous material cause or contribute to personal injury? El Yes Bl No If yes, enter the number of injuries resulting from the hazardous material:

Hospitalized (Admitted Only): Employees Responders General Public Non-Hospitalized: Employees Responders General Public (e.g.: On site first aid or Emergency Room observation and release)

35. Did the hazardous material cause or contribute to an evacuation? El Yes 0l No If yes, provide the following information:

Total number of general public evacuated _ _ Total number of employees evacuated Total Evacuated .

Duration of the evacuation (hours)

36. Was a major transportation artery or facility closed? El Yes ED No If yes, how many? __ (hours)

37. Was the material involved in a crash or derailment? E1 Yes El No If yes, provide the following information: Estimated speed (mph): _ Weather conditions:

Vehicle overturn? El Yes 0 No Vehicle left ro.adway/tra ck? El Yes 01 No PART V - AIR INCIDENT INFORMATION (please refer to § 175.31 to report a discrepancy for air shipments)

38. Was the shipment on a passenger aircraft? El Yes 0 No If yes, was it tendered as cargo, or as passenger baggage?

El Cargo [E Passenger baggage

39. Where did the incident occur (if unknown, check the appropriate box for the location where the incident was discovered)?

El Air carrier cargo facility El Sort center E[ Baggage area

[E By surface to/from airport [E During flight El During loading/unloading of aircraft

40. What phase(s) had the shipment already undergone prior to the incident? (Check all that apply)

[E Shipment had not been transported [E Transported by air (first flight) El Transport by air (subsequent flights)

El Initial transport by highway to cargo facility [] Transfer at sort center/cargo facility Form DOT F 5800.1 (01-2004) Page 3 - Reproduction of this form is permitted

PART VI - DESCRIPTION OF EVENTS & PACKAGE FAILURE Describe the sequence of events that led to the incident and the actions taken at the time it was discovered. Describe the package failure, including the size and location of holes, cracks, etc. Photographs and diagrams should be submitted if needed for clarification. Estimate the duration of the release, if possible. Describe what was done to mitigate the effects of the release. Continue on additional sheets if necessary.

Event occurrencce: 09119108, -1100 hrs. Location: American Electric Power, Materials Facility, Brdgman MI,49106:

Description of Events provided by ThermoFisher:

Normally all shipments of this product are shipped direct from our facility in Germany to our customers. As a result, the Oakwood Village, OH facility has not been a point of distribution for this product.

The DA1-6CC units were returned to the Thermo Fisher Scientific Oakwood Village, Ohio facility as a new product return from a customer. The individual units were returned, packaged in unmarked fiberboard boxes. This is being addressed separately with this customer as a preventative action.

American Electric Power requested that the sources be removed from the product and sent to a separate address. Our customer service personnel generated a separate order for the shipment of the radioactive sources once they were removed from the DA1-6CC units. Reference customer order CO 130017.

The DA1-6CC units were pulled from stock and sent to the shipping department. Shipping personnel followed the notation on the order which indicated that the sources should be removed. The shipping personnel made the assumption that the sources were removed since there was no indication of the product being radioactive on the packaging as described above. Items were then mistakenly packaged and shipped as non haz-mat material.

Description of Events provided by American Electric Power:

On 09/19/08, the (2) area monitors were delivered to the AEP Materials Management Facility. The package was inspected and due to the waybill, the package was not inspected for radioactive material since the billof lading stated that the sources were to be shipped separately to'the DC Cook nuclear plant. The packages were then transported to the DC Cook nuclear plant where they were received onsite and custody transferred to the Radiation Protection Department (organization that ordered the items). When the packages were opened for inspection, the area monitors were to contain Sr-S0 check sources (2 total). The Radiation Protection Department immediately quarrentined the area monitors, removed the two check sources, then returned the area monitors to the materials management department for storage until the issue is resolved. Both check sources that were removed and placed in a secured radioactive material storage area.

A condition report was immediately generated and routed through the Environmental Department for review.

PART VII - RECOMMENDATIONS/ACTIONS TAKEN TO PREVENT RECURRENCE Where you are able to do so, suggest or describe changes (such as additional training, use of better packaging, or improved operating procedures) to help prevent recurrehce.. Provide recommendations for improvement to hazardous materials transportation beyond the control of your individual company. Continue on additional sheets if necessary.

Corrective Actions Initiated by Thermolisher.

All packaging has been labeled as radioactive; Change relevant part descriptions to include the word "radioactive".

Improve current work instructions to reflect a verification process for radioactive shipments.

Provide additional training of all personnel involved in radioactive shipments.

Work order will be submitted to investigate and implement an enhancement to the MRP system to flag or notify shipping personnel of radioactive items and shipments.

Corrective Actions Initiated by American Electric Power:

AEP Material Management Department has placed a hold on all ThermoFisher outstanding purchase orders.

Determine actions necessary to ensure we receive radioactive shipments from ThermoFisher that are properly packaged, marked, and labeled (assignment due 45 days).

PART VIII- CONTACT INFORMATION Contact's Name (Type or Print): Jon Harnrer Telephone Number: ( ) (269) 465-5901 Contact's Title: Environmental Manager Fax Number: ( ) (269) 466-2550 Business Name and Address: 1 Cook Place . Hazmat Registration Number (if not already provided):

Bridgman, MI 49106 E-mail Address: jhharner@aep.com Date: 10/08/2008 Preparer is: E0 Carrier El Shipper ED Facility 0l Other Receiver Form DOT F 5800.1 (01-2004) Page 4 Reproduction of this form is permitted