Event Notification Report for November 03, 2005

DEFICIENCY FOUND IN INTEGRATED SAFETY ANALYSIS PROGRAM

"BACKGROUND:

"Framatome ANP routinely vacuum transfers LEU powder into 55-gallon drums for storage in the BLEU facility 55-gallon drum warehouse. A change was implemented recently to also vacuum transfer LEU powder from 45-gallon drums into 55-gallon drums, also for storage in the BLEU facility 55-gallon drum warehouse.

"EVENT DESCRIPTION:

"On day shift November 3, 2005 at approximate 2:00 PST, a process operator vacuum transferred LEU powder enriched to (deleted) wt% 235U from a 45-gallon to a 55-gallon drum in the BLEU facility at the Richland site. This transfer was performed according to an approved standard operating procedure (SOP). This was the first such transfer under a recently approved nuclear criticality safety analysis (NCSA) part of the Integrated Safety Analysis (ISA)

"When the operator was preparing the newly filled 55-gallon drum for transfer to and storage in the warehouse, the Nuclear Inventory Management System (NIMS) would not print a label for the drum. Operations personnel contacted an NCS specialist about this issue. While troubleshooting this problem, the NCS specialist discovered that the LEU powder contained hydrogenous additives. He recognized that the Richland site ISA did not implement IROFS to prevent transfer of powder containing hydrogenous additives from 45-gallon to 55-gallon drums.

"At this point, the drum was sampled and locked in place pending further evaluation. The 45-gallon to 55-gallon transfer process was also placed out of service pending further evaluation.


"SAFETY SIGNIFICANCE OF EVENT:

"The safety significance of this event is very low. In accordance with the NCSA a 55-gallon drum filled with LEU powder, enriched to (deleted ) 235U with a bulk density of (deleted ) and containing (deleted ) wt% moisture, that is fully reflected by water has a keff of (deleted). A moisture value of (deleted) wt% is required in such a drum to reach a keff of 1.0.

"The drum involved in this event actually contained 115.4 kg of LEU powder enriched to (deleted) wt% 235U with a bulk density of (deleted) and containing (deleted) total moisture equivalence (moisture and moisture equivalent approved additives determined by follow up laboratory analysis). Based on total moisture equivalent content alone, the material in the drum would have to have more than (deleted) times the limit (deleted) and more than (deleted) times the actual amount (deleted) before criticality could occur in the drum. The actual enrichment and bulk density of the material involved in this event provide additional margin compared to the values required for criticality discussed in the previous paragraph.

"POTENTIAL CRITICALITY PATHWAYS INVOLVED (BRIEF SCENARIO(S) OF HOW CRITICALITY COULD OCCUR):

"Criticality could only occur if moderation control on the material placed in the drum is lost. This could hypothetically occur if powder containing over (deleted) times the allowed limit (deleted) were placed into the drum.

"CONTROLLED PARAMETERS (MASS, MODERATION, GEOMETRY, CONCENTRATION, ETC.):

"The process parameter controlled in this portion of the process is moderation.

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

"Within the 1SA the NCSA, E04-NCSA-323 version 3.0 accident sequence 1.4.1 description bounds this event. It states, "UO, powder containing greater than (deleted) wt% H2O equivalent is transferred to a 55-gallon drum from the BLEU powder preparation south addback station."

"Defense 1 for this accident sequence states, 'Moderation control: Any 45-gallon drum of UOX powder that does not have at least two independent determinations that it has (deleted) wt% or less moisture must be stored in a specially designated, locked storage grid to prevent accidental drum movement.' This is IROFS 1105 and was maintained throughout this event. At HRR, per SOP, if a drum contains greater than (deleted) wt% moisture and/or > (greater) wt% moisture equivalent additives, it is locked in a storage location. Only trained key custodians may unlock these storage locations for further processing or handling of the drum, Based on the moisture and moisture equivalent approved additive content of the powder, the drum involved in this event was not such a drum.

"Defense 2 for this accident sequence states, 'Moderation control: The programmable controller interfaces with NIMS to verify acceptable moisture content before it permits transfer valve to open.' This is IROFS 6002 and was maintained throughout this event for moisture content of the powder. As implemented, this IROFS does not verify that the powder to be transferred contains no hydrogenous additives. However, as an uncredited defense, before permitting the transfer valve to open, NIMS does verify that the powder contains s (deleted) wt% AZS and (deleted) wt% ALS, which is (deleted) wt% moisture equivalent approved additives. Therefore, on a total moisture and moisture equivalent basis, NIMS does verify that the powder contains less than (deleted) wt% total moisture equivalence. This is approximately (deleted) times less than the (deleted) wt% total moisture equivalence required to approach a keff value of (deleted).

"Defense 3 for this accident sequence states, Moderation control provided by an AEC [active engineered control]. An in-line moisture monitor is interlocked to shut off the vacuum blower and stop the rotary valve to prevent a significant amount of Uox powder containing greater than (deleted) wt% H2O from being transferred to the drum. This is IROFS 4704 and was maintained throughout this event for moisture content of the powder. This IROFS, however, will not detect dry hydrogenous additives.

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

"After discovery of the deficiency, the drum was sampled and locked in place pending further evaluation. The 45-gallon to 55-gallon transfer process was also placed out of service pending further evaluation."

ECCS LEAKAGE OUTSIDE CONTAINMENT

"A 0.02 GPM leak was identified on the inlet valve (1CV89) to the 11 seal injection filter. This leak equates to 4500 cc/hour. The leakage is outside containment and quantified IAW Leakage Monitoring and reduction program procedure SC.RA-AP.ZZ-0051. This leakage exceeds the 3800cc/hour limit as stated in UFSAR section 6.3.2.11 and GDC-19 to ensure control room habitability. Therefore ECG section 11 section 11.2 specifically 11.2.2.b applies for being in a degraded or unanalyzed condition. The 1CV89 valve was recently replaced as a scheduled activity during the current 1R17 refueling outage. The 1CV89 packing has been adjusted and the leakage has stopped. The leakage was to the floor to the liquid waste system. There was no personnel contamination or injuries due to the leakage.

"Current Plant Conditions: RCS temperature is 340 degrees, RCS pressure is at 1400 PSIG and stable, plant heat-up and pressurization is in progress IAW integrated operating procedures."

The leakage occurred from 10:30 to 12:30 EST. The valve has been tested and declared operable. Primary coolant activity is 0.828 microCuries per cc. There is no known steam generator tube leakage.

The licensee will notify the NRC Resident Inspector.

* * * UPDATE FROM LICENSEE (SAUER) TO HUFFMAN ON 11/23/05 AT 15:10 EST * * *

"On 11/03/05 at 1505, PSEG Nuclear made an 8 hour report in accordance with the 10CFR50.72(b)(3)(v) --(Event number 42114) - for ECCS leakage outside containment.

"Upon further investigation, it has been determined that the leak was within the guideline limits for the control room and off-site radiological exposure. Additionally, at the time of discovery, Salem Unit 1 was in Mode 4 coming out of its seventeenth refueling outage and 73 of the 193 fuel assemblies in the core were new fuel assemblies. Therefore, the actual core nuclide inventory would have been much less than the core nuclide inventory assumed in the design basis analysis. Therefore, the event of November 3, 2005 reported under 10CFR50.72(b)(3)(v) is being retracted."

The licensee will notify the NRC Resident Inspector. R1DO (Doerflein) notified.

SAFEGUARDS REPORT

Discovered vulnerability in a safeguards system that could allow access to a controlled access area. Compensatory measure have been initiated. The licensee will notify the NRC Resident Inspector. Contact the Headquarters Operations Officer for additional details.

*** UPDATE AT 11:47 EST ON 11/08/05 FROM EWERS TO KNOKE ***

"This is a retraction to a notification made in accordance with 10CFR73.71 on November 3, 2005, regarding a security safeguards breach of a vital area at Millstone 2, (NRC Event No. 42115). Upon further investigation and review, it has been determined that there was no breach of the security barrier in that the required barriers were visually inspected and found to be intact. Therefore, this event has been determined to be not reportable in accordance with 10CFR73.71." The NRC Resident Inspector has been notified. Notified R1DO (Miller)

TS REQUIRED COMPONENTS INADVERTENTLY RENDERED INOPERABLE DUE TO INADEQUATE REVIEW OF WORK CLEARANCE

"At 0200 on 11/03/05 a clearance was authorized that defeated the DW [Drywell] pressure high and Rx [Reactor] vessel low isolation features to valves in the Nuclear Closed Cooling System and Instrument Air Systems. The required T.S. [Technical Specification] actions after this discovery are that the plant should have been in Mode 3 at 1600 on 11/3/05. The clearance was removed and the circuit restored to operability at 0142 on 11/4/05. The time of discovery for the loss of safety function was 2345 on 11/3/05."

The clearance was to perform pre-planned maintenance activities. The licensee plans on entering this incident into their corrective action program and will issue a Condition Report.

The licensee informed the NRC Resident Inspector.

* * * RETRACTION ON 12/30/2005 AT 10:07 FROM KENNETH RUSSELL TO ABRAMOVITZ * * *

"An 8-hour notification was made on November 3, 2005, in accordance with 10CFR50.72(b)(3)(v)(D), Accident Mitigation. This report was made when it was discovered that a clearance had unintentionally deenergized a portion of the containment isolation logic. This logic would have prevented a containment isolation valve for the nuclear closed cooling system and a containment isolation valve for the instrument air system from closing on a signal due to high drywell pressure or reactor vessel low level as designed.

"The condition was determined not to be a loss of containment (leakage) function since each containment penetration also has an inboard containment check valve which is leak tested and is credited for preventing leakage. The check valves in both penetrations were successfully tested to be in conformance with 10 CFR 50 Appendix J Option B criteria in March 2005. The containment isolation (instrumentation) function was also not lost. Only the logic for Group 2A outboard valves was deenergized. This was a small portion of the outboard logic and had no impact on the inboard logic. Since neither the containment function nor the containment isolation function was lost, there was no loss of safety function for an accident mitigation function and EN# 42116 is retracted.

"As discussed in EN# 42116, a Technical Specification violation occurred and is reportable per 10CFR50.73(a)(2)(i)(B), as a condition prohibited by Technical Specifications."

The licensee will be submitting a written LER for the 10CFR50.73(a)(2)(i)(B) event. The licensee notified the NRC Resident Inspector.

Notified the R3DO (Hills).

AGREEMENT STATE NOTIFICATON - MISSING SHIPMENT OF RADIOACTIVE MATERIAL

On November 3, 2005, reported that a radioactive shipment was missing its contents.

On November 3, 2005, at approximately 2:30 pm, Spectratek Services received a call from Protechnics in Kilgore, TX. They stated a seven piece shipment of four (4) fiberboard boxes and three (3) 20-gallon drums had been received. The contents of one of the 20-gallon drums were not in the drum. The drum was to have contained an ammo box with two 25 pound lead shipping containers, each containing 40 millicuries of Antimony-124 used in oil and gas well completion studies. All packages had security seals in place when they arrived at the Protechnics facility in Kilgore. Notification was made to the Protechnics corporate office, the freight company, and the NM Radiation Control Bureau. Interviewing all employees involved in packaging the shipment resulted in written statements from them. The inventory has been double-checked and it appears the material balance is correct.

Security camera tapes have been reviewed showing the packaging area for 10/31/2005 (the day of the shipment). The tapes show the radioactive material being loaded into the containers and the containers being closed and they also show the shipment being loaded onto the freight carrier's trailer.

Members of the FBI and Homeland Security made visits while conducting their investigation. The investigation is ongoing. Notification was made to the inspector with the Environmental Monitoring Program, Radiation Branch, Department of State Health Services in Texas.

State of Texas also notified NRC. See EN-42118.