ML101940455
| ML101940455 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/08/2008 |
| From: | Southern Nuclear Operating Co |
| To: | Office of Information Services |
| References | |
| FOIA/PA-2010-0209 | |
| Download: ML101940455 (54) | |
Text
..
SOUTHERN NUCLEAR PLANT E.I. HATCH PAGE 1 OF 1 FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: NMP-EN-002 *
- DATA PACKAGE/FORM NUMBER: Figure 1 *
- MPL NUMBER: N/A *
- ft RTYPE: GG3.100 *
- (DOCUMENT CONTROL USE ONLY) *
- REFERENCE DOCUMENTS: *
- ft KEYWORDS: 10 CFR 50.75 Leak/Spill Decommissioning Record TOTAL SHEETS: 2 DOCUMENT RETRIEVAL DATE: MAY 2008 ACCEPTABLE I UNACCEPTABLE REVIEWED BY:
DATE: 5 REMARKS: Actions for Potential Groundwater Contamination Events ADM-0020 REV. 2 21 DC-DCX-002-OS
S-Southern Nuclear Oprating Company Nuclear NMP-EN-002 rOUrNS Management CONMContamination Actions for Potential Groundwater Events Version 1.0
- _,*...,- Procedure .,Page 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
5/1/08 Hatch Violet M. Coleman X Volume (gallons): Location of spill/leak Source of spill/leak 8200 1Y22-NO08A collection tank next to Subsurface groundwater
__ discharge structure Duration of leak/spill: Approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Gamma Activity (uCi/cc Tritium Activity (pCi/L) Total Area Impacted (ft2) 0 uCi/cc (monthly 4.67E4 pCi/L 250 ft2 composite)
PART 2 - Event Description Outside of Protected Area? (@ Yes E] No [I Unknown It unknown, what actions needed to determine?
Description of eventrissue Subsurface outfall 1Y22N008A underground collection tank (next to discharge structure) overflowed onto surrounding ground area. The pump failed due to dirt and gravel build-up that had seeped into the tank through a gap between the manway and extension piece. The amount of dirt and gravel eventually shut the pump down allowing the tank to overflow.
Actions Taken to Stop Spill or Leak A temporary pump was set up to pump the liquid tank contents into the discharge structure until corrective action could be taken. The dirt and gravel were removed from the tank and the pump restored to operable condition the next day.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Water soaked into the ground around the tank area. Some of the water ran down a gulley to the river.
PART 3 - Communications Condition Report Number: CR 2008105067 State Agency Notification: State of Ga. EPD, James Hardeman 13:15 CST 5/2/08 (informal (Describe what agency, notification) when and who)
NRC Notification (when and who) Site Resident -Phil Neibaum 0730 EST 5/2/08 Figure 1
SOUTHERN NUCLEAR PLANT E.l. HATCH PA I (OF I FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: NMP- 64 - a0?.
- DATA PACKAGE/FORM NUMBER: lA I
- MPL NUMBER: NIA *
- RTYPE: G 3. 100
- (DOCUMENT CONTROL USE ONLY) *
- REFERENCE DOCUMENTS:
- KEYWORDS: Aac~iOS -*Ffr Pceerrl *
- TOTAL SHEETS: 2 *
- DOCUMENT RETRIEVAL DATE: :3/1h /)8
- ACCEPTABLE V UNACCEPTABLE REVIEWED BY:
DATE: (/6~
REMARKS:
ADM-0020 REV. 2 21 DC-DCX-002-OS
Southern Nuclear Operating Company SOTo A Nuclear aaeetContaminationActions for Potential Groundwater MaNagement EventsVeso1.
I VersiN 10 NMP-EN-002 Procedure C E Page 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? SMill?
3/19/08 Hatch Violet M. Coleman X Volume (gallons): Location of spill/leak Source of spill/leak 2450 PB2-AU and PB2-AT Pullboxes Groundwater and unknown source located east/SE of U2 CST moat.
Duration of leak/spill: Unknown Gamma Activity (uCi/cc) Tritium Activity (pCi/L) Total Area Impacted (ft2)
PB2-AU 6.183E-8 PB2-AU 9.23E5 PB2-AT 8.68E5 60 ft2 PB2-AT 6.842E-8 PART 2 - Event Description Outside of Protected Area? 0l Yes El No 10 Unknown If unknown, what actions needed to determine? . Investigation in progress.
Description of event/issue Tritium concentrations, in excess of 20,000 pCi/L have been discovered in pullboxes PB2-AU and PB2-AT east/SE of the U2 Condensate Storage Tank. Tritium level for PB2-AU is 9.23E5 pCi/L, PB2-AT is 8.68E5 pCi/L. Three other pullboxes in line carrying these cables were also sampled and had higher than expected tritium levels (PB2-AQ 1.56E4pCi/L; PB2-AR 8.16E3pCi/L; PB2-AS 2.93E4pCi/L).
Actions Taken to Stop Spill or Leak Pumped down the pullboxes but no active leakage into the pit can be seen. Cable lines run through PB2-AU and into the next pullbox PB2-AT. These are also connected to PB2-AS, PB2-AR, and PB2-AQ which then enter the turbine building. Subsequent pullbox sample results for tritium have trended down.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Water in the pullboxes has been pumped into a tank and disposed of in a decon sink to be processed through the radwaste system. Monitoring of these pullboxes continues in order to determine the source of leakage.
PART 3 - Communications Condition Report Number: CR 2008103772 State Agency Notification: State of Ga. EPD, James Hardeman (informal (Describe what agency, notification) 1500 CDT 3/20/08 when and who)
NRC Notification (when and who) Site Resident -Jim Hickey 0730 EST 3/20/08 Figure 1
SOUTHERN NUCLEAR PLANT E.I. HATCH PAGE 1 OF I FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: Nm?- *G4* - 0(-O *
- DATA PACKAGE/FORM NUMBER: LIA *
- MPL NUMBER: ,LA *
- RTYPE: tOO liei3. *
- (DOCUMENT CONTROL USE ONLY) *
- REFERENCE DOCUMENTS:
KEYWORDS: Ac+i*ors -(I Poser*4 c Grou*rA4c)err
- TOTAL SHEETS: 3 *
- DOCUMENT RETRIEVAL DATE: 12 02/2 1o"0
- ACCEPTABLE / UNACCEPTABLE REVIEWED BY:
DATE: a',o REMARKS:
ADM-0020 REV. 2 21 DC-DCX-002-OS
Southern Nuclear Operating Company Nuclear Actions for Potential Groundwater NMP-EN-002 SOrMACOMPANY Management Contamination Events Version 1.0 Procedure Page 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
12/_26_/2007_ Hatch Violet M. Coleman X Volume (gallons): Location of spill/leak Source of spill/leak 5700 Piping for 1Y22N008A Subsurface drain outfall Duration of leak/spill: unknown Gamma Activity (uCi/cc) Tritium Activity (pCi/L Total Area Impacted (ft2) 0 2.49E4 pCi/L (conc. Of weekly 5000ft2 composite)
PART 2 - Event Description Outside of Protected Area? Z. Yes El No [] Unknown If unknown, what actions needed to determine?
Description of event/issue Original CR: During visual inspection of the newly installed permanent 1Y22N008A outfall, it was discovered that the piping between the transition piece and the collector tank had separated causing subsurface drainage water to leak down the trench and exit near the discharge structure on the surrounding ground. It is believed that the rain showers 12/25 caused the separation of the piping (piping is connected together every 20 ft.). It is estimated that approximately 3600 gallons had been lost to the environment rather than entering the collection tank. Currently the subsurface water is being captured in the tank, however it is partially .routed on the ground until repairs can be made. The average tritium concentration for this outfall is approximately 1.8E4 pCi/L. Due to the sensitivity of groundwater tritium issues, Environmental Affairs will notify the State EPD with an informaVcourtesy call (NMP-EN-002).
Update: Actual weekly tritium composite concentration for this event was 2.49E4pCi/L. Estimated volume due to the event was 5700 gallons.
Actions Taken to Stop Spill or Leak Reconfigured piping (used piping from the temporary system) to route outfall flow to the collection tank for proper discharge into the discharge structure.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Spill exited onto the ground (from subsurface outfall) and was soaked into the ground.
PART 3 - Communications Condition Report Number: I CR2007111302
Southern Nuclear Operating Company Nuclear NMP-EN-002 Mou m& Management Actions for Potential Groundwater Version 1.0 E-.S.-Y,."., POMouW WP r-of ced u re II Contamination Events Page 10 of 9 State Agency Notification: State EPD (Describe what agency, Jim Hardeman (12/26, by phone), (12/27, spoke with him in person) when and who) Updated Jim Hardeman (1/11/08 by phone)
NRC Notification (when and who) Site Resident 12/27/07 updated site resident in person 1/11/08 Figure 1
SOUTHERN NUCLEAR PLANT E.I. HATCH I PAGE 1 OF 1 FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: NMP-EN-002 *
- i*
- DATA PACKAGE/FORM NUMBER: Figure 1 *
- MPL NUMBER: N/A *
- RTYPE: GG3.100 *
- (DOCUMENT CONTROL USE ONLY)
- REFERENCE DOCUMENTS: NMP-EN-002 *
- KEYWORDS: 1 OCFR50.75(g) *
- Leak/Spill Decommissioning Record *
- TOTAL SHEETS: 11
- DOCUMENT RETRIEVAL DATE: 4/04/2007
- ACCEPTABLE _ UNACCEPTABLE REVIEWED BY: __ _ __ _ _ __ _ __ _ _ __ _ _
DATE: '-
REMARKS: This data is required to be stored for the life of the plant by 10CFR5075(a) and for Life of Plant+99 by ANI.
Descriotion: 2007 - Larue tritium soike in NW-10 well next to U-2 CST.
DescriDtion: 2007 - Larae tritium spike in NW-1 0 weil ne to U-2 CST.
ADM-0020 REV. 2 21 DC-DCX-002-OS
Southern Nuclear Operating Company Nuclear NMP-EN-002
'* *41UN Management Actions for Potential Groundwater V 1.0
,.=,*. - ProcmrWe Proced ure Contamination
,Page Events 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
4/04/07 E.I. Hatch Violet M. Coleman N/A N/A Volume (gallons): Location of spill/leak Source of spill/leak.
N/A Monitoring well NW 10 next to west No new leaks or spills identified side of U-2 CST showed significant tritium increase Duration of leak/spill: monthly NW10 tritium sample result increase from previous month Gamma Activity (uCi/cc) Tritium Activity (pCi/L Total Area Impacted (ft2)
No activity on gamma 6.99E4 N/A spectroscopy PART 2 - Event Description Outside of Protected Area? El Yes 0 Noý E Unknown If unknown, what actions needed to determine? N/A Description of event/issue Monthly sampling of well NW10 (west side of U2 CST) showed a tritium increase from 40,000 pCi/L to 69,900 pCi/L. This result was verified. Nearest ground water monitoring wells were sampled to determine ifthe tritium was migrating outward. These well (NW2A, NW2B, NW3A, NW3B) results were at previous background levels.
Actions Taken to Stop Spill or Leak Above ground piping and tank were checked. No visible leaks present.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Continuing to monitor, increased tritium sample frequency for NW10, gamma isotopic performed with results showing no activity present. Increase in activity possibly due to water in pump moat seeping through to ground under the slab.
PART 3 - Communications Condition Report Number: 2007103999 State Agency Notification: Env. Affairs notified Ga. State EPD (Courtesy Call, Jim Hardeman (Describe what agency, 4/5/07) when and who)
NRC Notification (when and who) Notified site: NRC resident (Jim Hickey, 4/5/07)
Figure 1
Condition Report: 2007103999 jStatus: FinalReview Required Entry Date: 04/04/2007 Unit, H2 Discovered: 04/04/2007 12:00:00PM Building: Yard Event:
By: William E Duvall III ;Elev: Date:
Phone: 8-692-5866 32- Time:
Dept: Hatch - Chemistry Sect: Chemistry Location:
Description of Condition:.
Tritium sample results from ground water well NW-10 Indicaie an increase In activity, from approximately 40,000 to 70,000 pCI.
NW-10 is newly installed ground'water well located just west on Unit 2 CST Transfer Pumps Enclosure. This well was placed in service on 10/9/06 and is being monitored onea monthly basis. This area has been visually inspected and no active leaks are present Disposition thisCR to chemistry to determine the cause of tritium Increase le. from new source or historical leak, Additional monitoring is being established to determine plume boundary and movement. Current and historical data confirms no trltum plume outside protected area. No regulatory notification required, but SNC Environmental Affairs scheduled to contact State EPD tomorrow as courtesy call.
What Is affected:
Ground water tritlum How Discovered:.
Routine Monitloring and Sampling per 64CHH-SAM-028" Work Ev'ent: WalkThrough:, No- Hold: No OPS Review Req: Yes Dispatch Comment:
Apparent Cause Is complete; however, due date will be extended with Mge's(WED) approval to give extra day for approprate reviews. This does not impact the operation of the plant due to the fact that this is an enironmental issue with tritium and there are no notifications to be made at this point.
tg 5-2-07 CR#2007103999 Tritium sample results from ground water well NW-10 indicate an Increase in activity from approximately 40,000 to 70,000 pCOiL. NW-10 is newly installed ground water well located just west on Unit 2 CST Transfer Pumps Enclosure. This well was placed inservice on 10/9/06 and is being monitored on a monthly basis. This area has been visually inspected and no active leaks are present. Disposition this CR to chemistry to determine the cause of tritium increase i.e. from new source or historical leak. Additional monitoring is being established to determine plume boundary and movement Current and historical data confirms no tritium plume outside protected area. No regulatory notification required, but SNC Environmental Affairs scheduled to contact State EPD tomorrow as courtesy call.
- 1. Problem Statement Tritium sample results from ground water well NW-10 Indicate an increase Inactivity from approximately 40,000 to 70,000 pCi/L.
- 2. Apparent Cause(s) and Cause Code(s)
(1)Why have ground water tritium activity results from the NW-10 well increased from 40,000 pCiiL to 70,000 pCi/L?
The ground water titum activity from NW-1 0 has increased due to a contaminated leak inside U2 CST Pump Moat, which is in close proximity to NW-10.
(2) Why did the U2 CST Pump Moat leak?
A pump seal leak on the U2 Condensate Transfer Pump was identified in condition report 2006110915 (November 2006). At that time, the U2 CST Pump Moat was flooded with approximately two feet of water. The pump moat had been coated with Decathane to help prevent leakage to the surrounding area. However, the increased amount of water coupled with small cracks in the moat barrier caused some of the water to escape to the surrounding area prior to being drained to radwaste. This water eventually migrated to NW-10.
(3) How did this water migrate to NW-10 so quickly (i.e., 6 months)?
Underground pipe going into the U2 CST Pump Moat was replaced by above ground pipe between October 2006 and April 2007. To accommodate the pipe replacement, a hole approximately 10' deep by 10' wide was excavated. The hole was located about 5 feet from NW-10. The resulting void in the soi6 expedited the migration of water from the U2 CST Pump Moat to NW-10, which increased the measured tritium levels at NW-10 alter several months.
Cause Code:
AIR&
Conditlon*Report: 2007103999 Status: Final Review Required Entry Date: 04/04/2007 Unit: H2 L2E: Man-machine Interface or Equipment Condition/Equipment Condition/Component Aging:
CST seal leak that flooded the pump moat coupled with the pump moat having small cracks to allow water to escape to surrounding areas have been determined to be the apparent causes of the increase tritium activity at the NW-10 well.
Event Investigation Due to the heighten awareness of ground water tritium Issues, a recent hydrology study was conducted to map the current ground water tritium plume of the site (there were previously identified/known historical leaks around the U1 CST). A recommendation from the hydrology study was to drill 12 new ground water wells at strategic locations around plant site. These wells were installed in September 2006. One of the new wells installed was NW-10 located on the west side of the U2 CST Transfer Pump Moat near the stairs. Baseline tritium results from NW-10 indicated 30.000 pCVL. Subsequent monthly sampling from this location Indicated similar results.
Other initiatives were also being performed to address possible leakage avenues for UL1 and U2 from thinning, underground piping in the vicinity of the CSTs and piping penetrating the respective CST Moats walls. As a result of the Initiative, sealing the visible cracks and painting the floors and walls of the U1 and U2 CST Moats was conducted. Decathane was selected as a paint sealant for this purpose. The Decathane coating on the U2 CST walls and floor was completed September 20, 2006.
On October 4, 2006, a leak on the U2 CST Transfer Pump Seal Water Line was identified and, as a result, approximately two feet of water was introduced Into the moat. The water remained in the moat until it could be drained to radwaste about 2 days later.
The monthly tritium sample of NW-10 taken March 22, 2007, measured 70,000 pCi/L, which was a significant Increase from previous result. Another sample was taken and re-analyzed to confirm the Increase.
It was then determined that a courtesy notification to the State and site NRC would be performed due to the verified increase of tritium at NW-10 and the sensitivity to ground water tritium issues. A draft of NMP-ES-002, Actions for Potential Groundwater Contamination Events, was used for guidance of this communication.
During the October 2006 flooding incident some of the water from the moat seeped through small crevices and into the ground, eventually being seen in the groundwater at NW-10 (shallow well about 20' deep) several months later. Since this discovery, weekly samples of NW-10 show another step-increase but have now leveled off (see sample results below).
Tritium results (pCi/L) for NW-10:
10/09/06 39500 11119106 36700 11/27/06 36900 12/07/06 36500 12/22/06 34200 Tritium results (pCi/L) for NW-1 0(cont.):
01/04/07 32800 01/25/07 30900 02/20/07 39500 03/22/07 69900 04/04/07 80400 04/16/07 95600 04/23/07 110000 04/30/07 107000
- 3. Broadness Review (Required for QA Audit Findings and recommend for equipment issues, otherwise optional): This is applicable to the areas around Ul CST moat and pump moat There has been leakage in the past from the moat and these are addressed by routinely monitoring for tritium as required by procedure 64CH-SAM-028-0.
- 4. Interim Corrective Actions:
- Visually inspect U2 CST Moats for active leak.(Complete:No leaks identified).
" Performed gamma isotopic of NW-10.(Complete:No gamma emitters identified)
Have HP perform a radiological survey of the U2 CST Moat area.(Complete:No contamination identified).
- Sampled other groundwater well near NW-10 for tritium activity changes.(Complete:NW-2A Indicated background).
- Increase sampling frequency of NW-10 to weekly(Complete).
" Consult hydrologist to determine feasibility of other possible sources.
- 5. Recommended Corrective Actions:
Continue increased sampling frequency until tritium activity is stable or decreases then resume frequency as specified by 64CH-SAM-028.
(Chernistry:8/10/07)
" Repair seal leak on U2 CST transfer pump as given in WO 2062378601. (Maintenance:complete)
" Replace underground piping entering U2 CST pump moat with above ground piping and fill hole.(Maintenance:completa)
" Consult hydrologist to determine tritum inputs in this area and update groundwater plume mapping.(Chemistry:6/1/07)
" Review data to ensure tritium spike was correctly identified and trend indicates no additional leakage in this area.(Chemistry:8/10/07)
Dispatch Reviewer: kdlong UserID:
Date: 4/4/2007 5:40:18PM I
S- ~ 'V
Condition Report: 20071039991 Status: Final Review Required I Entry Date: 04/04/2007 j Unit: H2 Equipment: N/A .NOT APPUCASLEO safety Clsm N Active: A Typal. S LoaMtor NucClass: Tag: Team: MAINT Category: Event, Operability Status:. Operable Tracking#t n/a TSLCO#: na. Type.' N/A Comment:
IPower. 100 Mode: Mode I RC.Temp: NOT RC Pressure: NOP I
Event Related Evolutions In Progress:-
Routine sampling 1mm. Reportable No Hours: Date: 'Time: NRC Rpt.#
Compensatory Actions Taken:
None Received Date: Severity Lev: 3 Reportable? [ Impact to Plant:
Short Explanation:
Explanation: n/a quired AnalyIWs Method JIM [J ACD) ReCA, 0 RCCA Resp. Dept:
Due Date: 5/3107 Disposition Resp. Dept: Hatch Chemistry Reviewed By:
Approved By: Closed By:
ITO, I PER DATE '"YPE NUM PRB/PORC review? D, Meeting Num: Date:
PRB/PQRC Comments ........ "
Per MRM on 4-6-07 CR has been escalated to SL-3 with an apparent tause, due date will be reset to re~flect 30Oda s. tg4-6-0 Major category: Other Safety func. affected: NA Cause Dept: Hatch - Chemistry Event
Description:
Event Code Group1: Chemistry Related Events/Other Water Systems/Environmental Event Code Group2:
Event Code Group3:
Event Code Group4:
-' - 'u-
Condition Report:. 20071d399,9.Saus inlRve eqie EnrDt:044/07 UtH Department: Hatch - Chemistry Status:
Section: Chemistry Final Review Required Person: Violet M.Coleman Prepared By: thgordon Date: 5/3/07 Approved By: weduvall Date: 5/3/07 Last Action Due 08/10/2007 Disposition:
Apparent Cause is complete; however, due date will be extended with Mgr's(WED) approval to give extra day for appropriate reviews. This does not impact the operation of the plant due to the fact that this is an enironmental issue with tritium and there are no notifications to be made at this point. tg 5-2-07 CR#2007103999 Tritium sample results from ground water well NW-10 Indicate an increase in activity from approximately 40,000 to 70,000 pCI/L. NW-10 is newly installed ground water well located just west on Unit 2 CST Transfer Pumps Enclosure. This well was placed in service on 10/9/06 and Is being monitored on a monthly basis. This area has been visually inspected and no active leaks are present. Disposition this CR to chemistry to determine the cause of tritium increase i.e. from new source or historical leak. Additional monitoring is being established to determine plume boundary and movement. Current and historical data confirms no tritium plume outside protected area.
No regulatory notification required, but SNC Environmental Affairs scheduled to contact State EPD tomorrow as courtesy call.
- 1. Problem Statement Tritium sample results from ground water well NW-10 indicate an increase In activity from approximately 40,000 to 70,000 pCi/L.
- 2. Apparent Cause(s) and Cause Code(s)
(1) Why have ground water tritium activity results from the NW-10 well Increased from 40,000 pCI/L to 70,000 pCi/L?
The ground water tritium activity from NW-10 has Increased due to a contaminated leak inside U2 CST Pump Moat, which Is In close proximity to NW-10.
(2) Why did the U2 CST Pump Moat leak?
A pump seal leak on the U2 Condensate Transfer Pump was Identified in condition report 2006110915 (November 2006). At that time, the U2 CST Pump Moat was flooded with approximately two feet of water. The pump moat had been coated with Decathane to help prevent leakage to the surrounding area. However, the Increased amount of water coupled with small cracks in the moat barrier caused some of the water to escape to the surrounding area prior to being drained to radwaste. This water eventually migrated to NW-10.
(3) How did this water migrate to NW-10 so quickly (i.e., 6 months)?
Underground pipe going Into the U2 CST Pump Moat was replaced by above ground pipe between October 2006 and April 2007. To accommodate the pipe replacement, a hole approximately 10' deep by 10' wide was excavated. The hole was located about 5 feet from NW-10. The resulting void in the soil expedited the migration of water from the U2 CST Pump Moat to NW-1O, which increased the measured tritium levels at NW-10 after several months.
Cause Code:
L2E: Man-machine Interface or Equipment Condition/Equipment Condition/Component Aging:
-CST seal leak that flooded the pump moat coupled with the pump moat having small cracks to allow water to escape to surrounding areas have been determined to be the apparent causes of the Increase tritium activity at the NW-10 well.
Event Investigation Due to the heighten awareness of ground water tritium issues, a recent hydrology study was conducted to map the current ground water tritium plume of the site (there were previously Identified/known historical leaks around the Ul CST). A recommendation from the hydrology study was to drill 12 new ground water wells at strategic
___ aQe..... - - ReDor~GL.& c -in
Condition Report: 2007103999 1Status: Final Review Required Entry Date: 04/04/2007, Unit: H2 I locations around plant site. These wells were installed In September 2006. One, of the new wells Installed was NW-o1 located on the west side of the U2CST Transfer Pump Moat near the stairs. Baseline triltum results from, NW-1O Indicated 30,000 pIliL Subsequent monthly sampling from this location indicated similar results, Other Initiatives were also, being "pierfor*ed to address possible leakage avenues for Ul and UZ from thinning,-
un round piping In the Vicinity of the CST's and piping penetrating the respective CST Moats walls.. As a result
.of the Initlative, seallhg the visible cracks and painting the floors and walls of theiU1 and U2 CST Moats was conducted. Decathane was selected as a paint Sealant for this purpose. The Decathane coating on theU? CST walls and floor was. completedSeptember 20,'2006.
On October 4, 2006, a leak on the U2 CST Transfer Pump Seal Water Une was identified and, as a result; approximately two feet of water was.Introduced into the moat. The water remained In the moat until It could be drained to radwaste about 2 days later.
The monthly tritlum sample of NW-i0 taken March 22,2007,. measured 70,000 pCI/L, which was a significant.
increase from previous result. Another sample Was taken and re-anayze-d to confirm the ncrease.
It was then determined that a courtesy notification to the State'and site NRC would be performied due to'the verified increase of tritium at NW-I4 and the sensitivity to ground water tritium, issues. A draft of. NMP-ES-002, Actions for Potential Groundwater Contamination Eventsi was used for guidance: of this conmnunication.
During the October.2006 flooding Incident some of the water from the moat seeped through smallcrevices and Into the ground, eventually being seen in the groundwater at NW-10 (shallow well about 20'. deep) several months off (see later. Since"thIs discovery, weekly samples of NW-110 show another step increase but have now leveled sample results below).
Tritium. results (pai/L).for NWW1O:
10/09106 319s00 11/19/06 36700 11/27/06 36900
- 12/07/06 -36500
,12/22/06 34200.
Tritium results (pC/,L) for NW10(contj):
01/04/07 32800 01/25/07 30900 02/20/07 39500 03/22/07 69900 04/04107, 80400 04/i6/o0 9S600 04/23/07 .1'10000 04/30/07 107000
- 3. Broadness Revliew(Requlredfor QA Ai~lt Fndings and recommendfor equipment Issues, otherwise optional), This is applicable to the areas around UI CST moat and pump moat. There has been leakage In the:
past from the moat :and these-areiaddressed by routinely: monitoring for tritiun as required by procedure 64CHl-SAM-028-0.
- 4. Interim Corrective Actions:
Visually Inspect U2 CST Moats for active leak.(Compietei:o leaks.Identifled).:.
Performed gamma Isotopic of NW-10.(Comrplete:No gamma emitters Identified)
Have HP perform a radlological survey of the U2 CST Moat area.(Complete:No contamination Identified).
- " Sampled othergroundwater well near NW-10 for triturn activity changes,(Complet.e:fNW-2A indicated background).
Increase sampling frequency ofNW-10 'to weekly(Complete).
Consult hydrologist to~determine feasibility of other possible sources.
- 5. Recommended Conective Actions:
CContinue Increased sampling frequency untli tritium activity is stable or~decreases then resume frequency as specified by 64CH-SAM-028. (Chemlstry:8/10/07)
Repair seal leak on U2 CST transfer pUmp, as given in W02062378601. (Maintenancexcomplete)
Replace underground piping entering.U2 CST pump moat with aboveground piping andfill nole.
(Maintenance~complete)
Consult hydrologist to determine tritiurn Inputs.In this area and update groundwater plume mapping.
(Chemistry:6/1/07),
Review data to ensure tritlurm spike was corectl*yIdentifled and trendindicates no additional leakage Inthis area.(Chemlstrv:8/101071 I I
~yis~d'~ I 7~ ~ . e ~ ~ * ~ -R -o d.w.......
Condition Report: 2007103999 Status: Final Review Required' Entry Date: 04/04/2007 1 :Unit: H2 Maint. rule scope? No Function Failure?. N/A 14 this an MPFF? No 3ustification By: thgordon 4/5107 MR assigned to:-
3ustification:
N/A Status: Final Review Required Event desc. or failure scenario:
CR#2007103999 Tritium sample results from ground water well NW-10 indicate an increase in activity from approximately 40,000 to 70,000 pCI/L. NW-10 Is newly installed ground water well located just west on Unit 2 CST Transfer Pumps Enclosure. This well was placed in service on' 10/9/06 and Is being monitored on a monthly basis. This area has been visually inspected and no active leaks are present. Disposition this CR to chemistry to determine the cause of tritium Increase i.e. from new source or historical leak. Additional monitoring Is being established to determine plume boundary and movement. Current and historical data confirms no tritium plume outside protected area. No regulatory notification required, but SNC Environmental Affairs scheduled to contact State EPD tomorrow as courtesy call.
- 1. Problem Statement Tritium sample results from ground water well NW-10 indicate an Increase in activity from approximately 40,000 to 70,000 pCi/L.
- 2. Apparent Cause(s) and Cause Code(s)
(1) Why have ground water tritlum activity results from the NW-10 well increased from 40,000 pCi/L to 70,000 pCI/L?
The ground water tritium activity from NW-iO has increased due to a contaminated leak inside U2 CST Pump Moat, which is in close proximity to NW-10.
(2) Why did the U2 CST Pump Moat leak?
A pump seal leak on the U2 Condensate Transfer Pump was Identified In condition report 2006110915 (November 2006). At that time, the U2 CST Pump Moat was flooded with approximately two feet of water. The pump moat had been coated with Decathane to help prevent leakage to the surrounding area. However, the increased amount of water coupled with small cracks in the moat barrier caused some of the water to escape to the surrounding area prior to being drained to radwaste. This water eventually migrated to NW-10.
(3) How did this water migrate to NW-10 so quickly (I.e., 6 months)?
Underground pipe going into the U2 CST Pump Moat was replaced by above ground pipe between October 2006 and April 2007. To accommodate the pipe replacement, a hole approximately 10' deep by 10' wide was excavated. The hole was located about 5 feet from NW-10. The resulting void in the soil expedited the migration of water from the U2 CST Pump Moat to NW-10, which increased the measured tritium levels at NW-10 after several months.
Cause Code:
L2E: Man-machine Interface or Equipment Condition/Equipment Condition/Component Aging:
CST seal leak that flooded the pump moat coupled with the pump moat having small cracks to allow water to escape to surrounding areas have been determined to be the apparent causes of the increase tritium activity at the NW-10 well.
Event Investigation Due to the heighten awareness of ground water tritium Issues, a recent hydrology study was conducted to map the current ground water tritium plume of the site (there were previously identified/known historical leaks around the Ul CST). A recommendation from the hydrology study was to drill 12 new ground water wells at strategic locations around plant site. These wells were installed in September 2006. One of the new wells Installed was NW-10 located on the west side of the U2 CST Transfer Pump 2aQ22 _________ 12kprOGKW-
Condition Report: 2007103999 Status: Final Review Required Entry Date: 04104/2007 Unit: H2
-v m-Moat near the stairs. Baseline tritium results from NW-10 Indicated 30,000 pCI/L. Subsequent monthly sampling from this location Indicated similar results.
Other initiatives were also being performed to address possible leakage avenues for U1 and U2 from thinning, underground piping In the vicinity of the CST's and piping penetrating the respective CST Moats walls. As a result of the Initiative, sealing the visible cracks and painting the floors and walls of the U1 and U2 CST Moats was conducted. Decathane was selected as a paint sealant for this purpose. The Decathane coating on the U2 CST walls and floor was completed September 20, 2006.
On October 4, 2006, a leak on the U2 CST Transfer Pump Seal Water Une was identified and, as a result, approximately two feet of water was introduced Into the moat. The water remained In the moat until It could be drained to radwaste about 2 days later.
The monthly tritium sample of NW-10 taken March 22, 2007, measured 70,000 pCi/L, which was a significant increase from previous result. Another sample was taken and re-analyzed to confirm the increase.
It was then determined that a courtesy notification to the State and site NRC would be performed due to the verified Increase of tritium at NW-10 and the sensitivity to ground water tritium Issues. A draft of NMP-ES-002, Actions for Potential Groundwater Contamination Events, was used for guidance of this communication.
During the October 2006 flooding Incident some of the water from the moat seeped through small crevices and into the ground, eventually being seen in the groundwater at NW-10 (shallow well about 20' deep) several months later. Since this discovery, weekly samples of NW-10 show another step Increase but have now leveled off (see sample results below).
Tritium results (pCi/L) for NW-10:
10/09/06 39500 11/19/06 36700 11/27/06 36900 12/07/06 36500 12/22/06 34200 Tritium results (pCl/L.) for NW-10(cont.): -
01/04/07 32800 01/25/07 30900 02/20/07 39500 03/22/07 69900 04/04/07 80400 04/16/07 95600 04/23/07 110000 04/30/07 107000
- 3. Broadness Review (Required for QA Audit Findings and recommend for equipment issues, otherwise optional): This is applicable to the areas around U1 CST moat and pump moat. There has been leakage in the past from the moat and these are addressed by routinely monitoring for tritium as required by procedure 64CH-SAM-028-0.
- 4. Interim Corrective Actions:
" Visually inspect U2 CST Moats for active leak.(Complete:No leaks identified).
" Performed gamma Isotopic of NW-10.(Complete:No gamma emitters identified)
" Have HP perform a radiological survey of the U2 CST Moat area.(Complete:No contamination identified).
. Sampled other groundwater well near NW-10 for tritium activity changes.(Complete:NW-2A Indicated background).
" Increase sampling frequency of NW-10 to weekly(Complete).
" Consult hydrologist to determine feasibility of other possible sources.
- 5. Recommended Corrective Actions:
Continue Increased sampling frequency until tritium activity is stable or decreases then resume frequency as specified by 64CH-SAM-028. (Chemistry:8/10/07)
" Repair seal leak on U2 CST transfer pump as given In WO 2062378601. (Maintenance:complete)
" Replace underground piping entering U2 CST pump moat with above ground piping and fill hole.
(Maintenance:complete)
. Consult hydrologist to determine tritium inputs in this area and update groundwater plume mapping.
(Chemistry: 6/1/07)
" Review data to ensure tritium spike was correctly identified and trend Indicates no additional leakage In this area.(Chemistry:8/10/07)
.o IdPil I8/ o M~i 1'z0 eo
e °. ... CR QA Record Condition Report: 2007103999 Status: Final Review Required Entry Date: 04/04/2007 T Unit: H2 investigation scope/broadness review
- 3. Broadness Review (Required for QA Audit Findings and recommend for equipment Issues, otherwise optional): This Is applicable to the areas around U1 CST moat and pump moat. There has been leakage in the past from the moat and these are addressed by routinely monitoring for tritium as required by orocedure 64CH-SAM-028-0.
Is this a repeat event? No Was Previous RCCA adequate? N/A Repeat event review:
n/a L Other train/channel/unit checked 5 Other similar process checked 5 Other similar component LI Pencil and Paper narrative 5 Cause identification worksheel *] Apparent cause
['* Fault tree analysis determination Barrier analysis E/
5 Change analysis L Kepner-Tregoe analysis U Event and causal factor flow char. Other:
Description of causes:
Cause Code:
L2E: Man-machine Interface or Equipment Condition/Equipment Condition/Component Aging:
CST seal leak that flooded the pump moat coupled with the pump moat having small cracks to allow water to escape to surrounding areas have been determined to be the apparent causes of the increase tritium activity at the NW-10 well.
Cause Dept 1: Hatch - Chemistry Cause Dept 2:
Cause Dept 3:
Groupi: Man-machine Interface or Equip Cond/Equipment Condition/Component aging Group2:
Group3:
Group4:
Item Description DueDate Responsible Dept. .
Section Concurrence? ResPon.Person ConcurApp Date Al .
1 -T7his Corrective Action Is a result of a SL3 CR. 8/10/07 Hatch - Chemlstry Action to take:
Continue increased sampling frequency until tritium activity
.is stable or decreases then resume frequency as specified by 64C1H-SAM-028. (Chem0stry:8/tO/07)
Chemistry j] Stephen R Hodgins thgordon 5/3/07 2007201702 2- This Corrective Action Is a result*of a SL3 CR. 7/20/07 ".Hatch - Chemistry Action to take:-
Consult hydrologist to determine tritium inputs in. this area .
and update orouindwater lpume magping ..Chemistr..vj07Q)
Chemistry Terri H.Gordon thgordon 5/3/07 2007201703 3 This Corrective Action is a result of a*SL3 CR. 8/10/0.7 Hatch..- Chemistry Action to take:
'Review data to ensure tritium spike was correctly identified*
and trend Indicates no additional leakage in this area.
(Chemistry: 0 V Mo10 Chemistry Violet M. Coleman thgordon 5/3/07 2007201704 1 A'epvIsPed: 8/13/2007. . ace-8-oL Q Rer)or~tCROARico~rd.f.Ljt...
Condition. Report: 2007103999 Status: Final Review Required Entry Date: 04/04/207 Unit: H2 SSequence of event(s),documents attached
= Personnel, statement(s) documents attached.
Event(s) review documents attached.
RCCA prepared by:* ftOrdon 513/07 RCCAmapproved by; weduvall 5/3/07 RCCA final approver: weduvall 5/3/07 Documents: (DCMT) Ver Class Title Entity DocumentumID Ver. Type Doc. Num.
Apparent Cause Farm 2007 103999.DOC VCRT XX200129173 1.0 F 2007103999.DOC Apparent Cause Form 2007103999.DOC VCRT XX200129186 1.0 F 2007103999.DOC MPS Documents:
ClMs LM9 Titl DoIDntity Resolution document TABL System gen AI#2007201702 2007201702 VCRT Resolution document TABL System gen AI#2007201703 ý2007201703 VCRT Resolution document TABL System gen AI#2007201704 2007201704 VCRT LWeb Documents:
lass Te Title URL Property alue oa
SOUTHERN NUCLEAR PLANT E.I. HATCH IPAGE 1 OF 1 FORM TITLE:
RETRIEVAL CODE SHEET ft.
DOCUMENT NUMBER: NMP-EN-002
- DATA PACKAGE/FORM NUMBER: Figure 1
- MPL NUMBER: N/A RTYPE: GG3.100 (DOCUMENT CONTROL USE ONLY)
- .PE t NMP-EIN-002 REFERENCE DOCUMENTS:
ft ft
- ft
- ft ft KEYWORDS: 10CFR50.75(g) ft ft ft Leak/Spill Decommissioning Record ft ft ft TOTAL SHEETS: 13
- DOCUMENT RETRIEVAL DATE: 5/20/20b5 ft ft ACCEPTABLE UUNACCEPTABLE REVIEWED BY.:-____
DATE: . ~-* "
REMARKS: This data is required to be stored.for the life of the Plant by 10CFR5075(a) and for Life of Plant+99 by ANI.
Descriotion: 2005 - U-1 CST transfer pump recirc and suction line weld cracks leaked water to soil.
ADM-0020 REV. 2 21 DC-DCX-002-OS
. I '. I Southern Nuclear Operating Company souml110Am Nuclear Management Actions for Potential Groundwater NMP-EN-002 Version 1.0
.. COMPANY Procedure Contamination Events CiPage 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
5/20/05 Hatch William Duvall Yes NA Volume (gallons): Location of spill/leak Source of spill/leak Unknown U-1 pump recirc pump and transfer line Deteriorated and cracked piping Duration of leak/spill: Unknown __
Gamma Activity (uCi/cc) Tritium Activity (pCi/L) Total Area Impacted (ft2)
None Max. 1.02E+06 pCi/L Underground PART 2 - Event Description Outside of Protected Area? El Yes Z No; El Unknown If unknown, what actions needed to determine? /
Description of event/issue U-1 CST transfer pump recirc line leaks and transfer pump suction line weld cracks resulted in an unknown volume of seepage of CST water to the surrounding soil over the mid 2005-2006 time frame.
Tritium levels in nearby T12 well reached 1.02E+06 pCi/L. (CR# 2005105510, 2005104789 attached).
Actions Taken to Stop Spill or Leak Pipes were isolated and replaced.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Leaks were above ground, but were partially hidden under insulation. The water seeped through cracks in the concrete or grouting into soil beneath the boncrete pad. Nearby monitoring wells are sampled on a periodic basis by procedure.
PART 3 - Communications Condition Report Number: CR# 2005105510, 2005104789 State Agency Notification: GA DNR, Jim Hardeman (Describe what agency, when and who)
NRC Notification (when and who) Site and Region 2 inspectors Figure 1
Condition Report: 2005105510 Status: Transmitted Entry Date: 05/20/2005 Unit-: H2 Discovered: 05/2012005 3:55:00PM Building: Condensate Storage Tank Event:
By: James D McDonald Eiev: 130 ft. Date:
Phone: 8692-2183 'Room: Codensate Storage Tank Enosur Time:
Dept: Hatch:- Health Physics Sect: Health Physics Location: 2P.1F093 Desaiption of Condition:
2P1IF093 had 1hl flow leakage of contaminated condensate water onto the deck of the CST Tank Moat. The CST tank moat was already, posted
.opened by aclearance.
as contaminated Opsarea. U2 Control personnel R6 m SS said leakage was notifi.d and Ops personnelrarvel:d later to closed* the opened valve which was leakage by other 2P11.valves possibly was the. reason for the leakage out of this opened valve.
What is affected:
Leakage of Condensate water from Condensate system into CST Tank moat and increased radwasta.
Additional contamination to access and walking areas of CST Tank moat.
How Discovered:
HP Monthly CST survellience Status (005) Equipment Related . COMP Work Event WalkThrough: No Hold No OPS Review Req: Yes Dispatch Comment:
John Quattlebaum will determine which valve is leaking by.
From: Ouattlebaum, John C.
Sent:Thursday, June 16, 2005 12:56 PM To: Champion, J. Ben Cc: Clac. Lawrence R.
Subject:
CR's Ben, I have an open CR
- 2005105510, to resolve this CR we will have to wrlte and hang a tagout and open a drain valve and place sonic flow detection devices on the piping. I would like to get this as an AIT to give ample time to write the ragout and troubleshootlng plan and install the flow detection devices.
AIT 2005202062 initiated to track completion of this work. No further actions am required.
Dispatch Reviewer. keehunte UserID:
Date:, O 5120/2005 ý16:52PM Equipmenbt 2P111F093 IGLOSE GV-242 Safe"t aa :. N Active: A Type: VAL: Location:
Nuc. Class: N Tag: Team: 4AINT Condensate Storage Tank.
Category: Event- Unit 2 Operabnlity status: Operable Tracklng*. n/a TSLCO*:.n/a Type: N/A Corfmmnt: ri/a I Power 10 Mode: Mode 1 RC Temp: NOT RC Pressure: NOP EetRelated Evolutions In Progress:
Stagout .... _ . _ _
- ~'
- j. Condition Repot: 2005105510s Status: Transmitted I Entry Date: 05/20/2005. Unit: H2
%min No Hours Date: T ihe: NRC Rpt. J Compensatory Actions Taken:
Tagout 2-DT-05-2P11-00148 restored. Leak was from a drain valve that was open on the tagout. Leak has been stopped and Isolated. N further action required. SS reviewed.
Received Date: 5/23/05 Severity Lev: 4 Short Explanation: N/A Reoprtable? [F] Impact to Plant: Others Explanation: N/A Required Analysis BCD 11 AC:D[--"] RCCA IRCCA Resp. Dept:
Due Date: 6/17/05 Disposition Resp. Dept: Hatch - Operations Reviewed By: jbchampl 5/23/05 1:43 pm Approved By: jbchampi 5/23/05 1:44 pm Closed By: Jacob B. Champion III 6/17/05 11:19 am ITITLE TO iPER DATE 'T*PEINr I PRB/PORC review? -- Meeting Num: Date:
PRB/PORC Comments
-1 major category: Other Safety func. affected: NA Cause Dept: Hatch - Operations Event
Description:
Event Code Group1: Operational Related Events/Gasket Or Seal Or Gland Or Packing Or Equipment Leakage/Water Leak Event Code Group2: Operational Related Events/Equipment Or Component Failure Or Damage/Valve leak by Event Code Group3:
Event Code Group4:
i I Department: Hatch - Operations Status:
Final Review Required Section; General:
person: John C Quattlebaum Prepared By: Jbchampi Date: 6/17/OS Approved By: Jbchampi Date: 6/17/05 Last Action Disposition:
John Quattlebaum will determine which valve Is leaking by.,
From: Quattlebaum, John C.
Sent, Thursdayi June 16, 2005 12:56 PM To: :Champion, J.Ben Cc: Clarýk,Lawrence R.
Subject:
CR!'s Ben, t have an open Ck # 2005105510, to resolve this CR we will have to write and hang a tagout and open a drain valve'and place sonit flow detection devices on the piping. Iwould like to getrthis as an AfT to give ample time to write the tagout and troubleshootinq plan and install the flow detection devices;.
Aeii:
Condition Report:.2005105510 I Status: TransmittedI Entry Date: 05/20/2005 j Unit: HZ I I Maint. rule scope? Yes Function Failure? No Is this an MPFF? No 3ustification By: jbchampi 5/23/05 MR assigned to:
Justification:
This leakage did not Impact system operability. The m/r was not impacted.
Status:
Event desc. or failure scenario:
Investigation scope/broadness review Is this a repeat event? Was Previous RCCA adequate?
Repeat event review:
I.
ý Other train/channel/unit checked [jjOther similar process checked DiOther similar component Wý Pencil and Paper narrative [ICause identification F pparent cause etermination
- Barrier analysis ["Fault tree analysis LI Change analysis E1Kepner-Tregoe ED Event and causal factor flow char. Other:
Description of causes:
Cause Dept 1: Hatch - Operations Cause Dept 2:
Cause Dept 3:
Group1:
Group2:
Group3:
Group4:
mil r iie R i Section Concurrence? Respon.Person ConcurApp Date At,
conamon Report: zoV:1zuublu btatus: iransrnmcca tntry uate: uzIjl*z!UU.J unit: mz Sequence of event(s) documents attached Personnel statement(s) documents attached.
Event(s) review documents attached.
RCCA prepared by:
RCCA approved by:
RCCA final approver:
Ver Entity DocumentumlD Ver. Type Doc. Num.
/
[MPS Title
,Class QA Record QA Record - Version 1.0 VCRT AR200213232 1.0 F CR:2005105510 Documents:
Web- ocuments: MPS Doc.
IM EMS Entl Resolution document TABL System gen AI#2005202062 2005202062 VCRT Class Ttl R Iye
Condition Report: 2005104789 I Status: Transmitted I Entry Date: 04/28/2005 I Unit:. Hi Discovered: 04/2812005 11:00:00AM Building: yard Event:
By: William E Duvall: III Elev: Date: 11/07/2003 Phone: 8-692ý5866 Time: 12:00:00AM Dept: Hatch - Chemistry Room:
Sect: Chemistry Loction:
Description of Condition:.
Based on a trend review of ground water sampling the tritium rislts,from well T-12 spliked to 4.07E6 MpCiI on Nov 7, 2003. Tritiumlevels did not return to previous based lIne values until Nov 9f.2004. Well T412 is located southwest of Unit 1 CST moat. This well T12 has historically trended higher than other sample points but this was:thehfl* significant increase since 2001, This CR is being Initiated to ensure this ikreased trend is formally investigated to Identify the cause. No state or regulatory reporting requirements have been exceeded. Please disposition this CR to Environmefntal AffatirsSN-groupo:
What is affected:
High tritium concentration in ground water at Unit 1 CST How Discovered:
While reviewing sample trends during ANI inspection.
CR Type Status (033) Program Related COMP Work Event: WalkThrough: No HOld: No OPS Review.Req: No Dispatch Commen.t:
An AMprn Cause OdattnetaIOM Raport was wrie to address the Issue inthis CR and is atachedrin the Event 06OarIPlion or Failre SWIenarofld.
AN commen - et Manager must review deipsilion and appatent cause prior to closure.
The Apparent Cause Deteefnainaon haes been approved by the Acting Chemnistry Manager (JDB). AlN Action Items he been accepted by.the respect"v depaitment manages The duo data offt CR ha* been changed to13/ M. 5/2 CAE1 ..
Dispatch Reviewer sbrogers UserID:
Date: 4/28j/005 12:31:36P-Equilpment:
Safetyasa
- Active,,: Type: Location:
Nuc. Clasm: Tag- Team:
+Cateoty: +Event:
Operability Status: Tracking*:
TSLCO*: ~Tye:
Comtment?
Power WA Mode: N/A RC Temp: W/ RC Pressure: N/A Event Related Evolutions In Progress:
N/A Imm. No,. Hours Date: Time: NRC Rpt.
Compensatory Actions Taken:
Initial review by DOspatcher determined that Ops Review not required I 4g ep9~
Condition Report 2005104789 Status* Transmitted Entry Date: 04/28/2005 Unit. Hi Condition R7na , Ut Received Date: 4/28/05 Severity Lev: 3 Reportable? Impact to Plant: Economic Short Explanation: n/a I Explanation: At ANI exit, AGMPO requested that this CR be. classified as SL3. KAU 4/29/2005.
The due date of this CR has been moved to 12/30/05 to match the due date of the last Action Item that is due. CAE 5/26/05 1 RCCA Tab, page 4, "Approved by" and *Fnal Approved by" resigned to comply with proper equired Analysis BCD 13 ACD j3 RCCA II]RCCA Resp. Dept: Corporate - Environmental Affairs tJ Due Date: 12/30/05 Disposition Resp. Dept:', Corporate - Environmental Affairs Reviewed By: mjcorbit 12/30/05 1:42 prn Approved By: cmdixon 4/29/05 1:14 pm I Closed By: Matthew John Corbitt 12/30/05 1: 59 pm TiTLE PRB/PORC review?
i,iPER 13 Meeting Num:
I DATE Date:
TYPE i NUM PRB/PORC Comments I
Major category: Other Safety func. affected: NA Cause Dept: Corporate - Environmental Affairs Event
Description:
Event Cede Group1: OtherEvents/Others/Other Event Code Group2: Chemistry Related Events/Missed Chemistry Samples/Out of sped.
Event Code Group3:
Event Code Group4:
Department: Corporate - Environmental Affairs Status:
Section: Corporate - Environmental Affairs Final Review Required Person: Mary Beth Lloyd Prepared By: dahostet Date: 5/10/05 Approved By: dahostet Date: 12/29/05 Last Action Disposition:
An Apparent .Cause Determination Report was written to address the issues In this CR and is attached. in the Event Description or Failure S enar!o field.
AN14 Recommendation,*- Department Manager, must review diSplsitian aand apparent cause priorrto closure..
The Apparent Cause Determination has been apnagvedrby the Acting Chemistry Manager (38).g All Action Ite0 s have been accepted by the,respective department., .managers. The due dateWo this CR has been chainged to.12/30/OS. CAE Maint. rule scope? N/A Function Failure? No Is this an MPFF? No Justification By: cmdixon 4/29/05 MR assigned to:
Ia 9, 1
Condition Report: 2005104789 Status: Transmitted Entry Date: 04128/2005 Unit: H1 I
Ion:
Status: Final Review Required Event desc. or failure scenario:,
PROBLEM STATEMENT Based on a trend review of ground water sampling from well T12 on the southwest side of the Unit 1 CST moat, tritium levels spiked to 4.07E6 pCi/I on Nov. 7, 2003. Well T12 tritium has historically trended higher values than other sample points with several spikes in its history, but this was the first significant increase since 2001.
APPARENT CAUSE(S) AND CAUSE CODE(S)
Why did the ground water tritium in well T12 spike up by an approximate factor of fifteen over the course of six months in 2003 to a level approximately ten times higher than ever seen before?
During the investigation for CR #2005104789, data from over the past 20 years from Hatch piezometer wells around the Unit 1 CST moat was reanalyzed and new trend lines plotted. The trending graph for the T12 well over 20 years of data shows that the amount of tritium In the well has been increasing In general since about 1992. The graph also shows what appear to be four peak time frames over that 20 year period. These peaks appear to last for several sample periods over the course of anywhere from six months to two years and then they drop back down slightly above where they started from.
Possibilities of why the peaks could be occurring, in order of reasonable probability are:
- 1) A continuous small leak with occasional higher levels of tritium is occurring from the Unit 1 CST or associated piping.
- 2) A sporadic leak of some nature Is occurring from the CST or associated piping on a random basis and as the tritium decays and is dispersed In the ground the tritium level decreases back to near pre-peak levels.
- 3) Tritium from the SFP spill In the mid 1980's or some of the leaks described In the historical documentation Is gradually seeping down to the wells over the years with some isolated pockets of the water (with higher tritium values than the diluted surrounding ground water) getting Into the wells sporadically. However, this scenario seems unlikely since approximately two tritium half lives has passed. For the 2004 sample at 4.07E+06 pC0/I, the original SFP water or water leaks would have had to have a tritium concentration of about 1.6E+07 pCi/I.
Why has the tritium in T12 and other wells around the Unit 1 CST moat trended upward over the past twenty years?
Data from six other wells directly around the Unit 1 CST were trended. These six wells were not sampled as frequently as T12, but their data starts at the same time and continues through 2002 for two of the wells and through 2004 for the other four wells. All six wells show elevated levels of tritium from 1985 until the sampling was stopped. In 5 of the wells the tritium appears to be trending upward from mid 1992 until the sampling was halted. The sixth well (T1S) was trending downward until about 2000 and 2001 where It shows a marked spike in tritium which then dropped back down to near pre-spike levels by 2004.
Possible causes for the Increasing trends of tritium In these seven wells are the same as in the first why statement above.
Why has the tritium In the wells around the Unit 1 CST moat averaged two orders of magnitude or more above that found In the river?
The tritium levels for these wells In the ground water data base show elevated tritium levels from the start of the database in 1985. This implies the tritium was first introduced, previous to this database. The only explanation for the elevated and Increasing tritium over natural levels such as in the river water is that the tritium was introduced into the ground water by some manmade process ahd may have continued to be introduced either continuously or sporadically over the years. It is unknown what the ground water tritium levels are outside the protected area around Hatch, but the river water tritium values are known all the way back to pre-op days.
River water tritium values have ranged from <MDA to 358 pCi/I.
CAUSE CODE(S)
K5B - Managerial Methods (INPO Code): Corrective Action: Corrective action for previously identified problem or previous event cause was not adequate to prevent recurrence..
BROADNESS REVIEW (Required for QA Findings, otherwise optional)
Historical Documentation - excerpts taken from a document sent to the site In 2001:
M ý_p
_2 P1110
Condition Report: 200,5104789 1 Statust Transmitted I Entry. Date: 0,4/28/2005 1 Unit: H1 Condition .: .eport..Stats
.005.4.89. TrnmtedEty ae 42820l U Hi
,it Plant Hatch On-Site Tritium In Groundwater Monitoring Introduction*,
S4veral questions have been raised concerning thePlant Hatch Groundwater Monitoring. program. This report summarizes the history of the pogam and details thecourrent sampling and repotng ,requirements for the program,. It also addresses the question of whether any wells,. specifically wells P138 and TI can be.dropped from the program.
The discussion of th program In this summary Is not intended to report on the events that contributed to thie elevated levels of tritium In the on-site groundwater samples or on the historical levels of tritlum detected. This report covers only the rhistory of the sampllng and reporting commitments as the program evolved and the status of the program over the past five years.
References:
64-CH-ADM-001-OS - procedural sampling requirements for on-site groundwater H3 wells:
64-CH-SAM-004-OS - sampling procedure FSAR 2.4.13 Groundwater Reportable Occurrence Report 50-321/1979-021:and all revisions and updates through 1984 Pre-Op REMP Program REMP Reports 1974 through 1983 Data sheets HPX-0s06 *Release Via Unplanned Route- Groundwater' Discussion Pre-op Through 1985:
The Pre-op Radiological Environmental Monit0rng rPam (REMP) Induded twoon-sltewells, one on-site subsurface drainage ditch, and one off-site background location. Technically, on-site wells would not be part of the REMP program and it is, not clear why on-site samples were Includiedin the pre-op. However, It is not completely out of the ordinary. During pre-op both on-slte and off-slit samples were taken for several different media. Groundwater samples were taken as foilows: Grab sample Quarterlylan 1972,to Augý J1973; Grab sample.
Annually Aug 1973 to Jun 1974; Grab sample Quarterly Jun 74 to Sep :1974.
The 1974 REMP Report, ,which covered September 12 through December 31, 1974, did not Include groundwater data. An undated memo to file from Bil OWlinger stated that the on-slte groundwater sampling should be' stopped because It was not: required. A supplemental RE-MP report statedthat groundwaiter was not analyzed' during the 4thtquarter of 1974 because It was not required by the Environmental Tech Specs (ETS).
The 1977 REMP Report stated that the.ETS required oneindicator and one background location for groundwater sampling but indicated that groundwater ,samples were only required In the event of an accdent or unusual circumstance. Although not required,. samples were collected 6Caslonally from two deep wells, a subsurface
.dranage ditch, and three plezmeters. The 1977 4th (Qarter reuts were reported ina the REMP report as "very not specify Reporting Level.
high* for two of the eight samples (north outfall and N-7-A). TheETS did The new ETS for Unit 2 went Into effec November 16, .1978. The new Unit 2 ETS did not require groundwater sampling but they did establish a Reporting Level for tridum in,environmental water samples of 3 0 E4 PCI/L Theold Unit 1,ETS which did require groundwater sampling In the event of an accident or unusual circumstance did not include a Reporting Level and required Non-Routine Reports only In the case of a "significant environmental Impact". In 1978 and early 1979, several on-sIte groundwater samples were found to have elevated tritlum levels. Discussion In the 1978 REMP report qU6stions whether a .Non-Routine Report was required.for the samples because the o'n-sitewells aere not "environmental samples" and should not be subject to the reporting levels. Finaltythe decisin to submit a NonRou0ine Report pursuant to ETS 3.2 and 5.7,2 was bethe In
.made order of source to th be conservative. The buried open pipe near ithe Recombiner Building, which was determined to Increased tritium levels, Was discovered in March 1979. This was reported to the NRC as LER 50-321/1979-021 and Included the Anomalous Measurement Report. The 1978 REMP report discusses the sampling frequency and results through June 1979.
Quarterly updates to LER 50-321/1979-021 provided a report of all samples that exceeded 3.0 E4 pCi/I and continued until 1984. The level 310 E4pCI/L was the Reporting Level for environmental water samples established by ETS. This was used as the cut-off level although the samples in question.were all on-site and therefore not "environmental" samples. In addition to these reports, the status of the groundwater tuithum monitoring program continued to be reportedinIthe Annual REMP reports througIh 1953although the on-site!
groundwater samples were not true REMP samples..
Letter number GM--84-1is, dated 2/8/84. from H. C2Nix to the NRC, statedthat after 1983 thie problem Would not be reported quarterly or anually to the ETS&This decision was based on a meeting with the NRC jpursuant on 12/19/83 where It was determined that the elevated tritium levels did not pose an environmental concern.
Thls letter dosed LER 50-321/1979-021 'and ended the quarter*y updates to the LER, but the letter also committed that special quarterly updates would continue o be provided to the NRC.:
Z FP 0
Condition Report: 2005104789: 1 Status: Transmitted Entry Date: 04/28/2005 Unit: H1
-. 5 These quarterly special reports were sent from L. T. Gucwa, Chief Nuclear Engineer Georgia Power, to the NRC and provided a report of all samples that were elevated. These reports were submitted from the 1st quarter 1984 to the 1st quarter 1985.
Letter number NED-85-582, dated 8/16/85 from Gucwa to the NRC, referenced the decision to cease reporting the groundwater data as updates to the LER or as part of the REMP after 1983 and announced plans to stop submitting the quarterly special reports as well. The commitment was made that although the reporting would stop, the "on-site groundwater monitoring program would continue and records would be maintained."
Letter number 85-4565, dated 9/12/85 from the NRC to Gucwa, was a response to the letter from Gucwa stating the intention of stopping the quarterly reports. The NRC allowed that because the intention was to stop the reporting only and not to change the "substance of the program" the proposal was accepted.
1985 to Present:
Regular reports are not required as long as the tritium levels remain In the expected range. There Is no reporting level for on-site groundwater samples and historically values as high as 8 E05 pCi/L have been detected. In comparison, the highest sample from the past five years was 4.6 E5 pCl/L In 1985, when the commitment to continue the on-site groundwater monitoring program was made, the program was not clearly defined In a procedure. In 1988, the program sample locationsand sample frequencies were outlined In procedure 64CH-ADM-001-OS Rev. 4. The groundwater sampling program continues to be managed in accordance with procedure 64CH-ADM-001-OS Rev. 16. Dropping a location from the program or changing the frequency of sampling will require a procedure change.
Location P13B has been dry since 1984. Sampling at this location began In 1982 after a condensate demin precoat tank overflowed In the Unit 2 Turbine Building. Well Pi3B and several others In the vicinity were sampled in the follow-up to that spill. Another well in the vicinity of P13B that is Included in the program is N5B.
However, samples have been unavailable at this location since 1993. The few samples that were collected at this well were very low levels, which indicates that the spill had not affected tritium levels at that well at that time.
Well T18 has been dry since 1988, but prior to that time, the levels were consistently in the E4 pCi/L range. In investigating the results of the Groundwater Monitoring Program in the vicinity of T18, which is near the CST-1, it was discovered that tritium levels at T12 had been elevated since May of 1999. Although the levels were above 3.0 E4, since these wells are on-site, the environmental Reporting Level does not apply and no special report was required. However, this increase should be noted and investigated to determine the possible cause.
The wells in this area should also be observed more closely to determine if the trend Is increasing for the entire area, which could indicate a new tritium source. See the attached table "Samples with Activity Greater Than 3.0.
E4 pCi/L since 1996" for a list of all elevated samples in the past five years and the attached graph "Quarterly Samples (1996 to June 2001)" for the trend at well T12.
Because of the Increase In levels at T12, which is near T18, It ISquestionable whether location T18 should be dropped from the program. However, T18 has been dry for over 10 years and there are several other wells in the vicinity to monitor any changes. T18 can be sampled if It seems appropriate, but it may not need to be regularly sampled.
In conclusion, the commitment was made to the NRC in 1985 that the groundwater monitoring program would be maintained in order to track the potential movement of tritium from the two distinct areas where it was detected. The first area is in the vicinity of the Recombiner Building where an open line was discovered in 1978.
The second area is near the CST-1 where pumps and possibly the dyke were found to be leaking in 1982. The groundwater monitoring program may be revised as long as it continues to monitor these areas for possible movement and for increases in tritium levels which could indicate new sources. This program should continue until the written NRC commitment is rescinded from and acknowledged by the NRC.
End of Historical Documentation RECOMMENDED CORRECTIVE ACTIONS Much data Involving ground water tritium at Hatch exists. The vast amount of data may show other problem areas; especially since Hatch spilled a substantial amount of spent fuel pool water on the ground back in the 1980's and had several other leaks around the CST and recombiner building In the past.
Recommendations for corrective actions include:
- 1) Establish or re-establish a sampling program for all pertinent wells including drinking water wells. Include trigger points for levels of tritium and/or other nuclides In ground water and drinking water which "a T______
CR QA Record -
Condition Report: 2005104789 Status: Transmitted Entry Date: 04/28/2005 Unit: HI require increased monitoring or other actions. (Chemistry) 1
- 2) Continue researching the archived ground water tritium data for possible causes and start dates and extent of the tritium to determine Iffurther actions are warranted. (Environmental Affairs)
- 3) Search historic operational data for events and Information which would help identify possible causes, dates, and the extent of the tritium to determine If further actions are warranted. (Chemistry)
- 4) Determine If past or present underground leaks from the CST and associated piping are the cause(s) for increased tritium levels. (Engineering) i Investigation scope/broadness review I
Is this a repeat event? Yes Was Previous RCCA adequate? N/A Repeat event review:
Ground water tritium from the plezometer wells around the Unit I CST have shown elevated levels of tritium since 1978. Sporadically over the years, there has been some spiking of the tritium levels and there has been a continous general increase in ground water tritium in these wells since 1992.
D-Other train/channel/unit checked []Other similar process checked [j ther si,milar component D Pencil and Paper narrative [*Cause identification FllApparen t cause
-determi, nation Barrier analysis -- Fault tree analysis Change analysis FD1 Kepner-Tregoe F-1 Event and causal factor flow char. Other:
I Description of causes:
The historical data in the "Event description or failure scenario' section above describes some of the causes for high tritium In the ground water In the past. -
Cause Dept 1: Corporate - Environmental Affairs Cause Dept 2: Hatch - Chemistry Cause Dept 3: Hatch - Engineering Support Group1: Managerial Methods (INPO Code)/Corrective Action/Inadequate to prevent recurrence Group2:
Group3:
Group4:
Item Description. ,DueDate Responsible Dept.
Section Concurrence? Respon.Person ConcurApp Date Al 1 Continue researching the archived ground water tritium data for 12/30/05 . Corporate - Environmental Affairs possible causes and start dates and extent of the irltlum to determine If further actions are warranted.
X- Mary Beth Uoyd dahostet 6/1/05 2005201807 2 Establish or re-establish a sampling program for all pertinent 12/30105: -.:HatcH - Chemistry wells including drinking water wells. Include trigger points for -
levels of tritlum and/or other nuclides In ground water and drinking water which require Increased monitoring or other -.
-actions. _ " "" , .. . .
Chemistry William E Duvail III mjcorbit 7/14/05 2005201808 3 Search historic operational data for events and information 12/30/oS' Hatch'- Chemistry which would help Identify possible causes, dates, arid the extent of the tritium to determine if further actions are warranted.
Chemistry MXatthew John Corbltt m-corbit 7/14/05 2005201809 Revised: -3/29/2007. Paae 6 of 7 RepQro"CR JkQABR ojr..:, L.t
Condition Report: 2005104789 1 Status: TransmittodE EntryDate: 04/28/200 15 Unit: H1.
~8O5201834
~ecr Ci Engineering Sequence of event(s) documents attached:
Personnel statement(s) documents attached.
Event(s) review documents attached. I RCCA prepared by: dahostet 5/18/05 RCCA approved by: mJcorbit 12/30/05 RCCA final approver: weduvall 12/30/05 Clhanged9 :espOns4le ueptr from '1Corf1at.e1nvtromelntaj SO to *Corpomate-EnvironmentnJ Affairs' due to
$'iCes department reorganization and renaming ofdepartment.'
....... S6/10/05 Documents: (DCNT) Ver Class Title Entity DocumentumlD Ver. Type Doc. Num.
QA Record QA Record - Version 1.0 VCRT AR200205792 1.0 F CR:2005104789 MP5 Documents:
Classu Ttle. MP5 Dm XD, Entit' Resolution document TABL System gen AI#2005201907 2005201807 VCRT Resolution document TABL System gen A1#2005201608 2005201808 VCRT Resolution document TABL System gen AI#2005201809 2005201809 VCRT Resolution document TABL System gen AI#2005201834 2005201834 VCRT Web Documents:
Class Type l l URL PoeV alue
SOUTHERN NUCLEAR PLANT E.I. HATCH PAGE 1 OF 1 FORM TITLE:
RETRIEVAL CODE SHEET DOCUMENT NUMBER: NMP-EN-002 DATA PACKAGE/FORM NUMBER: Figure 1 MPL NUMBER: N/A RTYPE: GG3.100 (DOCUMENT CONTROL USE ONLY)
REFERENCE DOCUMENTS: NMP-EN-002 KEYWORDS: 10CFR50.75(g)
Leak/Spill Decommissioning Record TOTAL SHEETS: 9 DOCUMENT RETRIEVAL DATE: 10/01/2004 a
ACCEPTABLE - _ E UNACCEPTABLE REVIEWED B DATE: /O-/5--C)2 REMARKS: This data is required -to be stored for the life of the olant by 10CFR5075(a) and for Life of Plant+99 by ANI.
Description:
2004 - U-1 radwaste pad moat overflowed from demin. water leak into yard drains.
ADM-0020 REV. 2 21 DC-DCX-002-OS
Southern Nuclear Operating Company Nuclear NMP-EN-002 scum .B 1 Pr Management Actions for Potential Groundwater Version 1.0 WLPA anagmenW Contamination Events Version 1 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
10/01/04 Hatch Jim Dixon. Yes NA Volume (gallons): Location of spill/leak Source of spill/leak 5,610 U-1 Radioactive Waste Processing Pad Demin water leaked through valve Duration of leak/spill: 165 minutes -- See 2004 Efflueht Release Report Table 1-6A Gamma Activity (uCi/cc) Tritium Activity (pCi/L Total Area Impacted (ft2)
See 2004 Effluent ' See 2004 Effluent Release Report Unknown Release Report PART 2 - Event Description Outside of Protected Area? El Yes Z No'l- Unknown If unknown, what actions needed to determine? i Description of event/issue Demineralized water line valve leaked into and overflowed moat around the U-1 Radioactive Waste Processing Pad. Approximately 5, 610 gallons of water flowed into a nearby yard drain with slight contamination in the water due to flowing through the moat area. (2004 Radioactive Effluent Release Report section 1.7; Email from Jennifer Reagin io Terry Sides 01/28/2005 write up on event).
Actions Taken to Stop Spill or Leak Upstream valve was shut. Nearby monitoring wells are sampled on a routine basis by procedure.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring None PART 3 - Communications Condition Report Number: 2004 Radioactive Effluent Release Report section 1.7 and email from Jennifer Reagin to Terry Sides 01/28/2005 with write up about the event are attached.
State Agency Notification: NA (Describe what agency, when and who)
NRC Notification (when and who) NA Figure 1
1.5 RadiologicalImpact Due to Liquid Releases Doses to a Member of the Public due to radioactivity in liquid effluent were calculated in accordance with the Offsite Dose Calculation Manual. Results are presented in Table 1-3A for Unit 1, and 1-3B for Unit 2, for all four quarters.
1.6 Liquid Effluents - Batch Releases Batch Release information for Units 1 and 2 is summarized in Tables 1-5A and
,, -a ]/ 1-5B, respectively.
1.7 %-quid Effluents - Abnormal Releases On October 1, 2004, a demineralized water line failed in the Unit I Radwaste Processing Building and overfilled the moat inside the building. Approximately 5,610 gallons of slightly radioactive water spilled from the moat. Some of the water from the posted contaminated area was absorbed into the ground and pavement surrounding the Processing Building. The remainder of the water entered yard drains in close proximity to the Unit 1 Radwaste Processing Pad. As a conservative measure for this abnormal release, absorption of water into the ground was not taken into account; therefore, 5,610 gallons was used for the discharge volume. The discharge duration was determined to be 165 minutes.
Samples were taken by Chemistry just upstream of where water was entering two affected yard drains. One sample, was taken from the north end of the Processing Pad and the other was obtained from the south end of the Processing Pad Trailer.
Both samples indicated small amounts of radioactivity with the south end being slightly higher. As a conservative measure, the higher-activity sample was used to calculate the gamma activity released to the yard drains - approximately 6.20 pCi.
Additional sampling was performed at the three outfalls (endpoints) of the affected yard drains for approximately four days after the abnormal release. The results from these samples yielded no identifiable activity. It should be noted, however, that the yard drains' outfalls do not discharge directly to the Altamaha River but to a beaver pond and swamp area located on the eastside of the plant site.
The additional, required calculationis (i.e., addition of H-3, Fe-55, Sr-89, Sr-90 and Gross Alpha activities) for determining the actual dose to the public from this abnormal release were performed and yielded a total discharge activity of 6.50 pCi. Based on these results, no annual or quarterly release limits were exceeded.
The affected ground (i.e., contaminated dirt) from the abnormal release was excavated and processed as Dry Activated Waste. Table 3-1 reflects the disposal of the dirt.
Abnormal Release information for Unit I is summarized in Table 1-6A.
5
T-ep 01a /A Sides, Terry W.
From: Reagin, Jennifer 0.
Sent: Friday, January 28, 2005 12:10 PM To: Sides, Terry W.
Subject:
Hatch Demin Water Line Spill
- Terry, Attached is a preliminary version of the info required by 50.75(g)(1) for the eventual inclusion in the Hatch site-specific cost study(tentatively set for 2006).
Please provide feedback as to whether you think the Info provide is suitable or lacking.
- Thanks, Jennifer Reagin X3310/2530 IMA/Innrl
P
- 0)
Demineralized water leak at the Unit-I radwaste processinc vad At approximately 1315 on Friday October V a water leak in the Unit-I radioactive waste processing pad was seen exiting the door of the building. Maintenance personnel immediately notified the Health Physics shift foreman who at that lime left to investigate with a Senior Health Physics technician. Upon arrival at the area, around 1330, the Health Physics Foreman notified the Health Physics Manager who was at that time attending the 1300 outage management meeting. The Health Physics Manager arrived at the scene at approximately 1340. At this time, and noticing the extent of the leak, mitigation effort commenced. The Assistant General Manager Plant Operations was notified that a leak had developed and to the known extent of what was occurring. At this time hie responded to the scene. HP personnel began surveying the area and all surveys conducted revealed that contaminatiou levels discovered did not meet posting criteria for a contaminated area. However, the area was posted as a precaution in parallel with other activities that were commencing at that time.
Upon noticing that radiation levels In the Unit-I radioactive waste processing building bad not increased due to the water leak and due to the fact that no levels of contamination were above detectable levels on commonly used HP instrumentation, a deduction was made that the water was most likely coming from a 1" demumineralized water line that was pressurized Inside the room. The radioactive waste support vendor entered the area with HP coverage and isolated the demineralLzed water line. The leak was stopped around 1400. The vendor then arranged the system so as to pump the water out of the room and iuto the plant radioactive waste systems therefore draining the room.
There is no floor drain associated with this area.
Health Physics personnel in coordination with facilities maintenauce and contract support were working In parallel to the above action to ensure that water leaving the building was mitigated as best as possible. A berm was constructed around one yard drain to slow the amount of water entering and a trench was dug prior to the yard drain to prevent further leakage into the drain. Another yard drain located across asphalt and running cast of the processing facility was also bermed with absorbent material and theu absorbent material applied to absorb any water present on the asphalt.
Samples were taken for analysis by HP and Chemistry persounel. These individuals pulled liquid samples from inside the room, soil samples from outside the room, a liquid sample prior to entering the western most and nearest yard drain and then 2 soil samples from outside the affected area to use as standards. Chemistry personnel were dispatched to where the yard drains exit the plant. These yard drains are sometimes referred to as "outfalls" and continuous sampling was conducted.
The General Manager and the Assistant General Manager Plant Support for Plant Hatch were notified of this event and also responded to the scene. Senior management ensured that all procedures were followed and that any further activities necessary to conmplete were addressed. Senior management also notified corporate management including the Hatch Duty Manager iu Birmingham and the Vice President for Plant Hatch.
All personnel that responded to this event and those that were.outside the affected area were surveyed by Health Physics personnel. After being surveyed, all personnel went through the personnel coutaminatiou monitors in the plant to ensure that uo contamination was present on their clothing. All personnel, including HP personnel that entered the area passed all exit monitors without any alarms.
While the leak cannot be quautified to the exact amount that came from the building a conservative measure is being taken based on the fact that at around 11:15 the Health Physics Manager had been in the area performing a housekeeping walk down of the respirator decon room and the outside areas.
At this time no water was present ou the asphalt or outside the building. The buildiug was not entered sit this time.
....... I
V This area is currently posted off and the radioactive waste processing room is locked and controlled by Health Physics.
1P Initial chemistry samples were taken just upstream of where water was entering two affected storm drains. One sample was pulled on the north end of process pad and the other obtained from the south end of the process pad trailer. Both samples indicated small amounts radioactivity with the sample on the south end being slightly higher. The higher activity sample was used to calculate the amount of micro-curies released to the storm drains, approximately 6.2 uCi.
Additional sampling is being performed at outfalls Y22-N022A, Y22-N024A and Y22.N025A (end-points) from the above mention yard drains as shown on the attached page. No activity has yet been identified from these points. Additional sampling will continue to determine if any activity reaches the final outfalls (endpoint). It should be noted that these outfalls Y22-N022A, Y22-N024A and Y22-NO25A do not discharge directly to the Altamaha river but to a beaver pond swamp area.
Based on these results no annual or quarterly release limits have been exceeded, although additional calculations are still required to determine actual dose to provide inclusion into the Annual Release Report.
Summary of calculation below.
Estimation of Volume Released: Start of release is based on last time an individual was in this area and observed no leakage from the building (11:1 5). The end of the release is based on when the demin water supply valve was closed (1400).
Flowrate from demin water line = 34 gpm.
165 mins Gallons released = 5610 gals Total sample activity = 2.910E-7 uCi/cc Micro-curies release = 2.910E-07* 5610 gals:* 3785 = 6.2 uCi
'SNC PLANT E. 1.W--TCH Pg ro oi iro DOCUMENT TITLE: DOCUMENT NUMBERt RevNer No:
I GENERAL CHEMISTRY SAMPLING 64CH-SAM-004-0 11.1 ATTACHMENT 1 Att. Pg.
TITLE: DEEPWELLS / DRAINAGE OUTFALLS / RIVER WATER I of 1 Sample I Location Sample Type Drainage Outfa~ls (RVUR) As Labeled (D River Water River Upstream of Plant Discharge Dip :sample U2 Cooling Tower Overflow To Storm Drains Same' Location as Drainage Outfall 02B Y22-NO25A Dip sample 0 'Take grab samples from flowing stream.
Minimum Sample Size - 1000 ml Bottle Type - Poly MGR-0009 Rev 4 r ...............
. Pg 16 of 20 SNrC PLANT E. I. HATCHIPa1of2 m
DOCUMENT TITLE: ?DOCUMENT NUMBER: Rev/Ver No:
CHEMISTRY MISCELLANEOUS TASKSI 64CH-ADM-001-0 22.0 ATTACHMENT 4 All. Pg.
TITLE: RELEASES VIA UNPLANNED ROUTES (ISOTOPIC AND 1 of I GROUNDWATER)
SAMPLING PROCEDURE: 64CH-SAM-004-0 Tas Rteenc ~ ~ reqtuoncy. '.P-(P All isotopes meet Environmental Gamma iCFR 50.72 (8) Quarterly MDC (except Isotopic IEN 80-06 Q e natural 64CH-RCL-006-0 0551 (pCi/mI) IEB 80-10 background OR world-wide
_ _ _fallout) (1)
Monthly Aux. Boiler Pipe Chase Sump, Y22-N008A, Y22-N024A, ýT3, N9B, :
All times Y22-N007A, Y22-NO12A Quarterly Tritium ADM PYS, P15B, T2, " 64CH-SAM-004-0 0506 (pCi/.) `12, P16 Annual.
TIO, TIl, T18, MN11, N5B, P13B, T4, T8, T13, T14, T15, T16, P17B, Al, N8B, T5. N1OB, N7A, P17A, T6, T7
( Obtain the following samples per 64CH-SAM-004-0, unless otherwise noted:
" Auxiliary Boiler Water ()
" Sewage Treatment Effluent (sample per 64CH-OPS- 001-0)
- UI and U2 RHR Service Water Heat Exchanger *A*and "B'loops
- 0) IF any isotopes are Identified other than natural background or world-wide fallout after a re-sample confirmation, THEN contact the HP I Chemistry Supervisor and initiate a Condition Report and specifically record on the Condition Report that a Safety Evaluation be written to satisfy 10 CFR 50.59 and IEB 80-10 (applicable to newly identified contaminated samples). When this condition is related to a previously identified event (for example, Fuel Pool Spill of 1986) and was documented by a 10 CFR 50.59 SCREENING / EVALUATION, an additional 10 CFR 50.59 SCREENING I EVALUATION will NOT be required.
C This is NOT the same sample point as Auxiliary Boiler Chase Sump sample point (for Tritium).
MGR-0009 Rev 4
'1
SOUTHERN NUCLEAR PLANT E.I. HATCH TPAGE 1 OF1 FORM TITLE:
RETRIEVAL CODE SHEET DOCUMENT NUMBER: NMP-EN-002 DATA. PACKAGE/FORM NUMBER: Figure 1 *
- S MPL NUMBER: N/A
- S.
RTYPE: GG3.100 *
(DOCUMENT CONTROL USE ONLY)
- REFERENCE DOCUMENTS: NMP-EN-002
- KEYWORDS: 10CFR50.75(g)
- Leak/Spill Decommissioning Record TOTAL SHEETS: 2 DOCUMENT RETRIEVAL DATE: 8/07/2003 ACCEPTABLE L UNACCEPTABLE REVIEWED BY:-__"____
DATE: /19 -/ s- -
REMARKS: This data is required to be stored for the life of the olant by 1 OCFR5075(Q) and for Life of Plant+99 by ANI.
Descrilption: 2003 - U-1 CST line qoing through base slab deteriorated allowinq leak to soil.
ADM-0020 REV. 2 21 DC-DCX-002-OS
Southern Nuclear Operating Company
- rmm* Nuclear Actions for Potential Groundwater NMP-EN-002 Nen10 Management
- COMPAY Contamination Events Version 1.0
,-V.,-.--, Procedure Page 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100" PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
8/07/03 Hatch William Duvall Yes NA Volume (gallons): Location of spill/leak Source of spill/leak Unknown Unit 1 CST area Piping deterioration Duration of leak/spill: Unknown Gamma Activity (uCVcc) Tritium Activity (pCL) Total Area Impacted (ft2)
None detected Max. 4.07 E+06pCi/L Unknown PART 2 - Event Description Outside of Protected Area? [I Yes 0 No EJ Unknown If unknown, what actions needed to determipone?
Description of event/issue U-1 CST line going through base slab deteriorated allowing CST water to leak out and get into ground.
(2003). Tritium in well T12 reached 4.07 E+06pCi/L.
Actions Taken to Stop Spill or Leak Section of deteriorated piping replaced. Nearby monitoring wells are sampled on a routine basis by procedure.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Leak was underground and under the CST concrete base slab. Nearby monitoring wells are sampled on a periodic basis as described in plant procedures.
PART 3 - Communications Condition Report Number: NA State Agency Notification: NA (Describe what agency, when and who)
NRC Notification (when and who) NA Figure 1
SOUTHERN NUCLEAR PLANT E.I. HATCH PAGE 1 OF1 FORM TITLE:
RETRIEVAL CODE SHEET
- t1
- DOCUMENT NUMBER: NMP-EN-002
- DATA PACKAGE/FORM NUMBER: Figure 1.
- MPL NUMBER: N/A *
- RTYPE: GG3.100 *
- (DOCUMENT CONTROL USE ONLY) *
- REFERENCE DOCUMENTS: NMP-EN-002 *
- KEYWORDS: 1 0CFR50.75(g) *
- Leak/Spill Decommissioning Record
- TOTAL SHEETS: 2 *
- DOCUMENT RETRIEVAL DATE: 6/01/2002 ACCEPTABLE _ UNACCEPTABLE REVIEWED~ BY: 4.4 ?~
DATE: / -5 o REMARKS: This data is required to be stored for the life of the plant by 10CFR5075(,q) and for Life of Plant+99 by ANI.
Description:
2002 - Contaminated soil found on east side of reactor buildings during road construction.
ADM-0020 REV. 2 21 DC-DCX-002-OS
w4,j i.p Southern Nuclear Operating Company souTM Am4 Nuclear Management Actions for Potential Groundwater NMP-EN-002 Version 1.0 Mangeen Contamination Events Procedure Page 9 of 9 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
6/01/02 Hatch Wayne Kirkley Unknown Unknown Volume (gallons): Location of spill/leak Source of spill/leak NA East side of Reactor Buildings Unknown Duration of leak/spill: Unknown Gamma Activity (uCi/cc) Tritium Activity (pCi/L) Total Area Impacted (ft2)
Unknown None' Unknown PART 2 - Event Description Outside of Protected Area? Li Yes 0 No . Unknown If unknown, what actions needed to determiri?
I Description of eventfissue 2002 -- Contaminated soil found on east side of eatrBuildings while digging for new Dry Cask Transportation road. Source unknown.
Actions Taken to Stop Spill or Leak No Leaks Identified.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring Soil was containerized and sent to radwaste processing. Nearby monitoring wells are sampled on a routine.basis by procedure.
PART 3 - Communications _
Condition Report Number: NA State Agency Notification: NA.
(Describe what agency, when and who)
NRC Notification (when and who) NA Figure 1'
I i SOUTHERN NUCLEAR.
PLANT E.I. HATCH PAGE 1 OF 1' FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: NMP-EN-002 *
- DATA PACKAGE/FORM NUMBER: Figure 1*
- MPL NUMBER: N/A *
- RTYPE: GG3.100 *
- (DOCUMENT CONTROL USE ONLY) *
- REFERENCE DOCUMENTS: NMP-EN-002 *
- LlrJVAIDlO*n~l. 1/I"t'CO* :7**
- F~-~ I VV%,F~II"I./*I Leak/Spill Decommissioning Record
- TOTAL SHEETS: 3 DOCUMENT RETRIEVAL DATE: 9/17/1998
.... **..* ....................* .... ** ....... I ......... **.. ............ .... ***
ACCEPTABLE <UNNACCEPTABLE_
REVIEWED BY:
DATE: r*e REMARKS: This data is required to be stored for the life of the olant by 10CFR5075(q) and for Life of Plant+99 by ANI.
Description:
1998 - Unit 2 Circ Water Blowdown Check Valve internal contamination ADM-0020 REV. 2 21 DC-DCX-002-OS
I Southern Nuclear Operating Company Nuclear NMP-EN-002 SIoHM'* em~* Management Procedure Actions for Potential Groundwater 7otmntinEet Version Page 1.09 9 of 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.100)
PART 1 - Location/Source Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
9/17/98 Hatch S.R. Hodgins NA NA Volume (gallons): Location of spill/leak Source of spill/leak NA U-2 Circ. Water Blowdown check valve See description below Duration of leak/spill: NA _
Gamma Activity (uCVcc) Tritium Activity (pCi/L) Total Area Impacted (ft2)
Several hundred cpm None , NA PART 2 - Event Description Outside of Protected Area? []Yes []No', Unknown If unknown, what actions needed to determine?
I Description of eventrissue U-2 Circulation Water Blowdown check valve internally contaminated. Believed caused by backup from U-2 Liquid Radwaste Discharge line while dilution flow was secured. (Internal Letter from S. R. Hodgins 1
to Tommy Elton about 1/2N71 -F008).
Actions Taken to Stop Spill or Leak Contaminated due to back up in discharge water.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring None PART 3 - Communications Condition Report Number: Internal Letter from S. R. Hodgins to Tommy Elton about 1/2N71-F008 (attached)
State Agency Notification: NA (Describe what agency, when and who)
NRC Notification (when and who) NA Figure 1
b7 DATE: September 17, 1998 Re: Plant E.I. Hatch 1/2N71 -F008 FROM: S.R. Hodgins TO: Tommy Elton It was recently discovered that unit 2 Circ H20 blowdown check valve 2N71-F008 was internally contaminated. This valve is located in the yard in a valve pit and was previously considered to be uncontaminated. We believe this was caused by discharge of liquid rad waste tanks with no dilution water fl&w present in the discharge line, allowing undiluted radwaste td back up to the check valve and contaminate it. This mode of discharge was implemented due to the unit 2 dual division service water outage, during which no source of dilution water was available on unit 2. This practice is used on both units, so the potential for contamination of this component exists on unit I and 2. For this reason, valve 1/2 N71-F008 and piping downstream to the liquid radwaste discharge line tee should be considered potentially contaminated and so listed on the Plant Decommisioning Plan. Please forward this to the appropriate people so that the Plant Decommisioning Plan can be so revised.
Steve Hodgins
SOUTHERN NUCLEAR PLANT E.I. HATCH Tp PAGE I OF I FORM TITLE:
RETRIEVAL CODE SHEET
- DOCUMENT NUMBER: NMP-EN-002 *
- DATA PACKAGE/FORM NUMBER: Figure 1 *
- MPL NUMBER: N/A *
- RTYPE: GG3.100 *
(DOCUMENT CONTROL USE ONLY)
- i*
REFERENCE DOCUMENTS: NMP-EN-002 *
- KEYWORDS: 10CFR50.75(g) *
- Leak/Spill Decommissioning Record
- TOTAL SHEETS: 7 *
- 'DOCUMENT RETRIEVAL DATE: 6/04/1997
- ACCEPTABLE . , UNACCEPTABLE REVIEWED BY: _________________
DATE: _-___ -- -_-o_ _ _
REMARKS: This data is required to be stored for the life of the plant by 10CFR5075(Q) and for Life of Plant+99 by ANI.
Deacrintion: 1997 - Site Land Fill 7 contaminated OiecAS nf concrete rubble Desceintion: 1997 - Site Land Fill 7 conta inated d6ces of concrete rubble ADM-0020 REV. 2 21 DC-DCX-002-OS
, I, Southern Nuclear Operating Company Nuclear Actions for Potential Groundwater NMP-EN-002 oummm Management CortmnainEvnsVersion 1.0
¢eM* Procedure Page 9 of 9 Procedur Con tamination Events 10 CFR 50.75(g) Leak/Spill Decommissioning Record (R-type GG3.1 00)
PART 1 - Location/Source___
Event Date Plant Name: Individual Contact Name: Check one: Leak? Spill?
6/04/97 Hatch Deryle Bennett NA Yes Volume (gallons): Location of spill/leak Source of spill/leak NA Site Land fill! Contaminated concrete ruble Duration of leak/spill: NA Gamma Activity (uCi/cc) Tritium Activity (pCi/L) Total Area Impacted (ft2) 1,000-2,000 dpm None, NA PART 2 - Event Descroption Outside of Protected Area? Z] Yes [I No: E] Unknown If unknown, what actions needed to determine Descripti~on of event/issue Owner Controlled Land Fill found to have seven'pieces of contaminated concrete rubble originating from demolition during remodeling of the U-1 Radwaste Building were found at the site Landfill during a surveillance survey. The material had been surveyed clean prior to release from the WSTSF. The contamination levels were about 1,000 to 2,000 dpm/probe area on a portable frisker. The seven pieces were removed from the Landfill and sent to radwaste. Disposal of additional concrete material from this project were halted from disposal in the Owner Controlled Landfill. Potential for more contaminated debris under the surface. (Nuclear Licensinci letter to NRC NL-5606 Enclosure 4).
Actions Taken to Stop Spill or Leak Methodology for releasing debris was changed.
Actions Taken to Clean-up Spill or Leak and Long Term Monitoring See Description above.
PART 3 - Communications Condition Report Number: Nuclear Licensing letter to NRC NL-5606 Enclosure 4 (attached)
State Agency Notification: NA (Describe what agency, when and who)
NRC Notification (when and who) Region 2, George Kuzo, 1997 Figure 1
Lewis Sumner M Southern Nuclear, Vice President operting Company, Inc.
Hatch Project Support 40 Inverness ParkwaY Post Office Box 1295
- e Birmingham, Alabama 35201
,' 'Tel 205 9927279 5
jA t~5Fax 205.992.0341 SOUTHERNZ.
COMPANY Enew to Serve Your Worldw April 7, 1998 Docket Nos. 50-321 HL-5606 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Edwin .1.Hatch Nuclear Plant Reply to.a Notice of Violation Gentlemen:
In response to your letter dated March 10, 1998, and according to the requirements of 10 CFR 2.201, Southern Nuclear Operating Company (SNC) is providing the enclosed response to the Notices of Violation associated with Inspection Report 97-12. In the enclosure, a transcription of the NRC item precedes SNC's response.
If you have any additional questions on this subject, please contact this office.
Sincerely, H. L. Sumner, Jr.
JAW/eb
Enclosures:
- 1. Violation 97-12-02 and SNC Rsponse
- 2. Violation 97-12-05 and SNC Response
- 5. Violation 97-12-09 and SNC Response
- 6. Violation 97-12-10 and SNC Response
U.S. Nuclear Regulatory Commission" Page 2 April 7, 1998 cc: Southern Nuclear OperalingCompanv Mr. P. H. Wells, Nuclear Plant General Manager NORMS US. Nuclear Regtlabory CommisSion. Washington. D.C.
Mr. L. N. Olshan, Project Manager - Hatch U.S. Nuclear Regilatory Commission. Region II Mr. L. A. Reyes, Regional Administrator Mr. B. L. Holbrook, Senior Resident Inspector - Hatch HL-5606
Enclosure 4 Edwin I. Hatch Nuclear Plant Violation 97-12-07 and SNC Response VIOLATION 97-12-07 10 CFR 20.2001 (a) requires disposal of licensed material to be made only by transfer to an authorized recipient as provided in section (§) 20.2006; by decay storage; or by release in effluent or as authorized under §§ 20.2002, 20.2003 or 20.2004.
Contrary to the above, as of June 4, 1997, licensed material was not disposed of in accordance with requirements in that seven pieces of concrete rubble contaminated with low levels of Cobalt-60 and Cesium- 137 radionuclides were found in the licensee's onsite landfill.
This is a Severity Level IV violation (Supplement IV).
RESPONSE TQ VIOLATION 97-12-07 Reason for the violation:
The seven pieces of concrete rubble originated from demolition performed during remodeling of the Plant Hatch Unit 1 radwaste building. From January, 1997 to June, 1997, the waste concrete rubble was moved to the Waste Separation and Temporary Storage Facility for survey and disposition.
Surveys of the concrete rubble were performed prior to its release by taking multiple smears (to detect removable contamination). and by direct frisk of the material. The surveys were performed using two different detectors: a gamma scintillation detector (Ludlum Micro-R meter) and a beta-gamma'Geiger-Mueller detector count rate instrument (hand held E-120). The surveys were documented per the applicable site procedures.
In response to an employee concern, a check of material released for disposal outside of the protected area was performed. This-check was performed at the site landfill by a Southern Nuclear Health Physics employee who identified and surveyed some concrete rubble in the landfill (identified to be from demolition of some of the radwaste building walls). This material was found to contain about 1000 to 1200 dpmlprobe area using similar survey techniques used when the material was released.
The regulation (10 CFR 20.2001 (a)) requires that disposal of licensed material to be made only by transfer to an authorized recipient as provided in section (§) 20.2006; by decay storage; or by release in effluent or as authorized under §§ 20.2002, 20.2003 or 20.2004.
HL-5606 E4-1
0 w Violation 97-12-07 and SNC Response In addition, the NRC has published two supplemental guidance documents to aid with the release of potentially contaminated material.
These supplemental guidance documents are IEC 81-07 and IN 85-92. The first document provides guidelines on how much effort was needed to ensure items being released are free of licensed material. It specifies a detection limit for the instruments used to release the material. It does not prescribe release limits. This document sets the minimum required detection limit for fixed contamination at 5000 dpm/ 100 cm2 and for removable contamination at 1000 dpm/l100 cm 2.
The second document, IN 85-92, gave further guidance on what a good monitoring program likely would include. It also defined "no radioactive (licensed) material" to mean no detectable radioactive material.
The cited regulation, as written, prohibits the release of any contaminated material, such that its radioactivity is zero. However, the:NRC has previously recognized that meeting the absolute requirement of this regulation is impractical (and unnecessary). As a result, they published the two supplemental guidance documents described above. In IEC 81-07, the NRC states that, "Analytical capabilities are available to distinguish very low levels of radioactive contamination from the natural background levels of radioactivity." However, the NRC has stated that "... these capabilities are often very elaborate, costly, and time consuming making their use impractical (and unnecessary) for routine operations."
The level of contamination found on the pieces of rubble removed from the landfill was found to be within the expected statistical variations of the associated instrumentation when the detectable contamination is near the lower limits provided in IEC 81-07. The Plant Hatch procedural guidance in place at the time is consistent with the IEC 81-07 guidance, and states that "Release surveys for beta-gamma contamination require radiation detection instrumentation to have a lower limit of detection (LLD) of 5,000 disintegrations per minute/100 cm 2 (dpm/1O0 cm 2) for large area proportional counters or 1000 disintegrations per minute (dpm) per probe area."
The quantity of the identified fixed contamination approximated the detection limit of the instrument. Variations between instruments, and personal surveys can realistically produce false negatives during one measurement and, a true positive during a subsequent measurement (or vice versa). In other words, when measuring radioactivity at or near the detection limit of any instrument, slight variations above the detection limit are to be expected due to the random nature of radioactive decay and variations in instrument sensitivity. Thus, at the time, SNC believed that the release was performed consistent with the NRC guidance.
HL-5606 E4-2
41 Violation 97-12-07 and SNC Response Corrective steps which have been taken and the resultS achieved:
The seven pieces of contaminated concrete rubble were retrieved from the landfill, and disposed of as radioactive waste.
SNC Health Physics management halted further disposal of concrete from the radwaste building demolition project in the owner controlled landfill. All additional concrete rubble generated from the project has been disposed of as radioactive waste.
SNC Health Physics management has stopped releases of any material from the waste separation facility to the landfill, without prior HP manager approval. This practice will remain in place until such time that release requirements can be clarified.
SNC Health Physics management was counseled on this event to ensure closer management involvement during work of this nature.
Corrective steps which will be taken to avoid further violations:
SNC Health Physics is in the process of clarifying the requirements for release of materials from the plant. Associated procedural enhancements will be in place by August 1, 1998.
Date when full compliance will be achieved:
Full compliance was achieved when the suspect pieces of concrete were removed from the landfill and disposed of as radioactive waste.
HL-5606 E4-3