Event Notification Report for May 28, 2003

DISCOVERY OF A CONTROLLED SUBSTANCE WITHIN THE KEWAUNEE PLANT PROTECTED AREA

"On 5/28/03 at approximately 0730 CDT on-site testing of a substance proved positive for a controlled substance. The substance was found by a member of plant staff on the plant grounds within the protected area. The plant staff member took possession of the substance and immediately contacted Security staff personnel for assistance. There were no personnel noted in the area of the substance [at the time of discovery]. After confirming the substance, it was turned over to Kewaunee County Sheriff's Department."

Contact the Headquarters Operations Officer for additional details.

The licensee notified the NRC Resident Inspector.

NRC BULLETIN 91-01, 4 HOUR REPORT

The following is taken from a facsimile report from the licensee to the NRC Operations Center.

"Short Description/Event Title: Enriched uranium rods mixed with Maine Yankee boron carbide poison rods.

"Consequences - details: This material was always within our control. The identification and tracking of the material was deficient. Additionally, the necessary controlled parameters to assure nuclear safety were not established or maintained for the specific location and configuration in which the rods were stored.

"Immediate action taken: Rod downloading personnel were instructed to obtain the pin-stamped number from each rod that is determined to contain uranium, which will aid subsequent investigation. The remaining rods in the storage box were evaluated for extent of condition, and the potentially containing uranium have been segregated to an approved location to further ensure their favorable configuration. Key personnel at Hematite and Columbia were also informed of the issue.

"Full Description: Three uranium-bearing fuel rods were identified at approximately 1630 hours on May 28, 2003 as part of a zircaloy scrap recovery project. The scrap recovery effort is being conducted inside the rod loading room of Building 230, and involves tubing from a Maine Yankee fuel fabrication campaign conducted by the previous owner, ABB, in 1997. The fuel was never shipped to Maine Yankee due to that plant's subsequent shutdown. The fuel rods were opened by ABB, and the enriched uranium pellets were recovered during the first quarter of 1998. The boron carbide (B4C) poison rods were not opened at that time. The B4C rods are now being downloaded by a Westinghouse sub-contractor for recovery of the zircaloy cladding. When opened, three rods from the last box to be downloaded were found to contain uranium pellets rather than B4C, Because of the potential of finding at least some pellets, all operations were being conducted under appropriate radiological controls. An additional 21 rods from that last box that have been identified as suspect due to their weight difference. They have been put aside at an approved location, but not yet opened for verification.

"Additionally, a separate box of rods containing what appears to be depleted uranium were also identified about two weeks ago. The preliminary determination of the contents being depleted uranium is based on their physical characteristics and markings. These rods are still under investigation to confirm that they contain depleted uranium.
During the period of storage, this material was stored in the warehouse portion of Building 230, which is located within the fenced and protected area of the site. This material was always within our control, but the identification and tracking of the material was deficient. In response to this issue the following actions have been taken:

"A review of the reporting requirements of 10 CFR Parts 70.50, 74.11, 73.71 and Appendix G of Part 73 established that this issue does not meet the requirements for formal reporting. Nevertheless, a courtesy call was placed this afternoon to the D&D Project Manager at NRC Region III. A high level CAPS item, has been established for tracking of all actions taken regarding this matter. A Root Cause Analysis will also be conducted. Consideration was given to whether this issue should be treated as an extension of the Kardex issue that was the subject of a separate report, but it appears that it would be appropriate to treat this matter separately due to the differing circumstances. Arrangements have been made to have an independent review conducted at the site to determine if additional measures should be taken in locating material. This is expected to occur next week.

"Plant management initially assessed this situation as unreportable to the NRC for material control aspects as noted above. It was also assessed as not reportable under NRC Bulletin 91-01, Supplement 1, 'Reporting Loss of Criticality Safety Controls,' because of the following criticality safety aspects:

"The as-found condition was bounded by existing analysis for rod channel boxes formerly used in the manufacture of fuel rods; The as-found condition was safe due to the extensive amount of absorber, in the form of B4C rods, surrounding the uranium rods; The as-found condition was safe due to the inability for introducing moderator because a lid was secured on the storage box. The box was stored on a cantilever rack that further precluded the possibility of flooding.

"Nevertheless, a courtesy call was placed within 24-hours of discovery to the facility's Project Manager at NRC Region III. Further review has determined that the as-found condition was not bounded by the rod channel box analysis, but is bounded by fuel assembly analyses. Additionally, the situation is now assessed as reportable under Bulletin 91-01 because the necessary controlled parameters to assure nuclear safety were not established or maintained for the specific location and configuration in which the rods were stored. A formal 91-01 report, Number 39897, has therefore been made to the facility's NRC Project Manager and the NRC Operations Center."

RPS ACTUATION

At 1134 EDT on 5/28/03, Calvert Cliffs Unit 2 experienced an automatic reactor trip. The cause of the trip appears to be loss of load caused by a main turbine trip on either reverse power or overspeed. The turbine trip may have been caused by planned troubleshooting on the turbine governor valve controls. All control rods inserted normally on the trip. One or both pressurizer power operated relief valves lifted and immediately re-seated following the trip. The steam generator atmospheric valves opened and immediately closed following the trip. All Emergency Diesel Generators and ECCS systems are operable, and the licensee plans to conduct a quick trip recovery.

The licensee notified the NRC Resident Inspector, and the Calvert County Control Center of this event.

BULLETIN 91-01 24-HOUR REPORT

At 1100 [CDT] on 5/28/03, approximately 1/8 inch layer of water was discovered in the bottom of NAM [Negative Air Machine] 2000-4 in the C-310 truck alley in violation of NCSA GEN-09. GEN-09 prohibits the use of NAMs on spraying/wet operations where intake could contain droplets of moisture. This control prevents uranium from being washed off the filters into an unsafe configuration in the bottom of the NAM.

The NRC Resident Inspector has been notified of this event.

PGDP Assessment and Tracking Report No. ATR 03-1592, PGDP Event Report No. PAD-2003-012.

SAFETY SIGNIFICANCE OF EVENTS:
The amount of fissile material accumulated in the bottom of the NAM, does not exceed residual quantities. This indicates, with high confidence, that less than a safe mass is present.

POTENTIAL CRITICALITY PATHWAYS INVOLVED (BRIEF SCENARIO(S) OF HOW CRITICALITY COULD OCCUR)
In order for a criticality to be possible, greater than a critical mass of uranium must be accumulated then become moderated.

CONTROLLED PARAMETERS (MASS, MODERATION, GEOMETRY, CONCENTRATION, ETC)
Double contingency is maintained by implementing two controls on mass.

ESTIMATED AMOUNT, ENRICHMENT, FORM OF LICENSED MATERIAL (INCLUDE PROCESS LIMIT AND % WORST CASE CRITICAL MASS):
Less than an always safe mass of uranium.

NUCLEAR CRITICALITY SAFETY CONTROL(S) OR CONTROL SYSTEM(S) AND DESCRIPTION OF THE FAILURES OR DEFICIENCIES

The first leg of double contingency is based on mass. NCSA GEN-09 requires that D/P measurements be performed for each NAM filter section each time the machine is placed in service and immediately prior to taking the machine out of service. This control provides a means for detecting material that has been removed from the filter into an unsafe geometry in the bottom of the NAM. These checks were performed; therefore, this control was not violated.

The second leg of double contingency is based on mass. NCSA GEN-09 prohibits the use of NAMs on spraying/wet operations where intake could contain droplets of moisture. This control prevents uranium from being washed off the filters and into an unsafe configuration in the bottom of the NAM. The control was violated since a water spray is used at the burp station to cool the cylinder. However, since only a residual amount of uranium (less than an always safe mass) was washed off the filter, the parameter has been maintained.

Since double contingency is based on two controls on one parameter, and a control was violated, double contingency was not maintained.

CORRECTIVE ACTIONS TO RESTORE SAFETY SYSTEMS AND WHEN EACH WAS IMPLEMENTED:

1. Change filters according to CP4-GP-BG2108.
2. Decon the residual amount of uranium at the bottom of the NAM according to CP4-CU-CH2103.
3. While investigating this incident, a concern was identified as to whether or not the system configuration has been adequately analyzed for NCS purposes. The NAM shall remain out of service until the system configuration issue has been resolved, at which time the exclusion zone and postings may be removed.