ML081550645

05/28/2008 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

1> AREVA -NRC meeting. Atlanta May 28, 2008 2> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.

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 Transportati on Radiation Limits Ron LandVP Manufacturing OperationsDominique Grandemange Plant Manager Valerio DunnFuel Services Project ManagerGeoffrey Wertz EHS&L Manager 3> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.

Presentation Agenda

>Background

>Fuel Cleaning Equipment Overview

>Timeline / Ri sk Assessment

>Causal Analysis/Corrective Actions

>Conclusions 4> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.BackgroundOn 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 indicat ed that Box 455 had a localized "hot spot" which exceeded the transportation requirements of 10 CFR 71.47.

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

Fuel Cleaning Equipment OverviewPurpose/Use:

• Ultrasonic cleaning system used to remove material deposits from the fuel cladding to reduce Axial Offset Anomaly improving thermal performance

• Secondary benefit to reduce plant source term -dose reductionSystem 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 components Fuel Cleaner Fuel AssemblyUltrasonic Transducer Housing Fuel Cleaner Filtration UnitPrimary Underwater Components:Filtration UnitUltrasonic Transducer Housing for Two Fuel Assemblies 6> AREVA -NRC meeting. Atlanta May 28, 2008Jan-08Feb-08Nov-07Dec-0710/24/07 Equipment shipped from Palisades.Highest contact reading on Box 455 was 80 mr/hr.10/26/08MAR receipt survey 80 mr/hr.1/31/08 Pre-shipment survey: FH remained 450 mr/hrHighest contact reading on Box 455 was 40mr/hr.Activity Timeline Pre-ShipmentInappropriate Action - 4Lessons learned from past events not applied.12/13/07 MAR equipment survey performed. Filter Housing (FH) - 450 mr/hr on contact.Pump - 7 R/hr - replaced.Pre-operational checkout - 12 hrs of operation (flushing) prior to package for shipment to WB. No change in radiation levels (fixed).Inappropriate Action - 2Containment of high activity material not sufficient for transport.Inappropriate Action - 3Equipment shipped on a flatbed trailer.

7> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Jan-08Mar-08Apr-08Feb-082/6-9/08 MAR RP Tech to WB to perform surveyreadings.2/4/08 WB received shipment with Box 455: hot spot reading 2000 mr/hr, 150 mr/hr at 4 inches below box (top of trailer bed), and 5-7 mr/hr beneath trailer.Discussed shipment with WB staff - equipment was being handled safelyReviewed shipment itinerary from trucking companyPerformed risk review and concluded no immediate risk to driver, public nor workers.WB unloaded the Box 455. Activity Timeline Post-Shipmen t2/9/08 Source material located in Box 455 and removed using duct tape.Box 455 returned to 1-2 mr/hr.2/19/08Source material returned to MAR.Reading 800 mr/hr behind 3/16" plate, 14 mr/hr at 1', and 2 mr/hr at 36".Isotopic Analysis -long-lived corrosion products.Inappropriate Action - 1 Waited to send HP to WBInappropriate Action - 5 No formal HP training on DRP.

8> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Summary of Survey ResultsGood Gamma Survey Data Consistency With No External Beta Contamination FoundMAR Survey DataWB Survey DataDetector : TELEPOLEDetector : TELETECTOR(gamma readings)800 mr/hr on contact2000 mr/hr gamma and beta on contact 25 mr/hr at 12 inches150 mr/hr at 4 inches No smearable contaminationNo smearable contaminationDetector : TELEPOLEDetector : RSO-5800 mr/hr on contact1500 mr/hr on contact (open window)70 mr/hr at 12 inches800 mr/hr on contact (closed window)Detector : TELEPOLE1 to 2 mr/hr on contactDetector : TELEPOLE1100 mr/hr on contactDetector : TELEPOLE800 mr/hr on contact14 mr/hr at 12 inchesOn hot spot removed from BOX 455 with 3/16" plate Performed at MAR OUTSIDE of box 455 Performed at WB INSIDE of box 455 Performed at WBINSIDE of BOX 455 after removal of "Hot Spot" Performed at WBOn hot spot removed from BOX 455 Performed at MAR 9> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Safety SignificanceSurvey data illustrated graphicallyConclusion of Risk Assessment : No Undue Risk to the Public or Truck Driver 10> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Causal Analysis & Corrective Actions

>Two Apparent CausesAC #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.

11> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Causal Analysis & Corrective Actions

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

• Thresholds trigger additional management review

• Applicable to all MAR equipment shipments.

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

• Enhanced ownership of equipment packaging.

12> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Causal Analysis & Corrective Actions

>Corrective Action #3Added 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 Equipmentis transported in a closed conveyance.

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

>CA's 1 -4 are completed 13> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.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 -Performed an external assessment of RP practices in shipment preparation -complete.

• Results matched internal ACA findings.#2 -Open CA to perform a Lessons Learned Review.

• Implemented through CAP and audit process.

14> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Contributing Causes & Corrective Actions

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

>Corrective Actions #1 -Procedure SL-1291,"Discrete Radioactive Particle Control" created#2 -RP technicians were trained on the procedure.#3 -Formal DRP Training Program developed.#4 -Initial & Recurring Training added to the RP annual curriculum.

15> AREVA -NRC meeting. Atlanta May 28, 2008AREVA NP Inc.Contributing Causes & Corrective Actions

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

>Corrective ActionRequirement to dispatch an RP technician immediately if a transportation container exceeds any transportation

limit.Requirement added to procedure SL -1600.

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

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