Event Notification Report for April 16, 2009

UNANALYZED CONDITION DUE TO POSSIBLE UNFAVORABLE GEOMETRY

"During a routine NRC inspection, the inspector questioned the adequacy of a 5-gallon limit on liquids allowed in certain process areas to prevent accidental nuclear criticality if the other controls in place are missing.

"While further investigation is underway, this event is being reported per 10CFR70 Appendix (b)(1) on a conservative basis.

"SAFETY SIGNIFICANCE: The safety significance is low

"POTENTIAL CRITICALITY PATHWAYS: Liquid from 5-gallon container would have to spill and all enter normally closed equipment, or uranium dioxide powder spilled from the equipment.

"CONTROLLED PARAMETERS: Controlled parameters are moderation

"CORRECTIVE ACTIONS: A prohibition of spillable liquids exceeding 3-gallons was established in the affected areas."

The licensee will be notifying the NRC Region 2 Senior Inspector.

REACTOR SHUTDOWN REQUIRED BY TECHNICAL SPECIFICATIONS

"At 1828 [CDT] on 4/16/09, it was discovered that the procedure for calibrating Low Steam Line Pressure Safety Injection Lead/Lag units may not ensure that the Tech Spec setpoint requirements were met. Calibration methodology used a ratio of lead over lag time constants to determine acceptance criteria. KPS [Kewaunee Power Station] Tech Specs Table 3.5-1 item 4 requires that the lead and lag time constants have individual ESF initiation instrument setting limits. When the error was discovered, data was reviewed from the most recent calibrations of the pressure channels. While the ratios met acceptance criteria per the calibration procedure, the individual lag time constants did not meet acceptance criteria per Tech Specs. Per TS Table 3.5-3 item 1c, all channels of the Low Steam Pressure/Line Safety Injection signal were declared inoperable. Per KPS Tech Spec 3.5.c., the plant must be placed in Hot Shutdown, as soon as practicable.

"Negative reactivity insertion began at 2004 [CDT] on 4/16/09. Therefore, this is reportable under 10 CFR 50.72(b)(2)(i) 'Initiation of a shutdown required by Tech Specs.' Since both trains of Steam Line Low Pressure SI channels are affected this is also reportable under 10 CFR 50.72(b)(3)(ii)(B) 'any event or condition that results in the nuclear plant being in an unanalyzed condition that significantly degrades plant safety' and 10 CFR 50.72(b)(3)(v)(D) 'any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.'"

At 2140 CDT, the reactor was at 56% power and hot shutdown is expected to be achieved at 2330 CDT.

The licensee notified the NRC Resident Inspector.

COMMINGLED WASTE

The following was received from the commonwealth via fax:

"On April 16, 2009, the Covanta Haverhill trash-to-energy plant requested a routine DOT-E 11406 for the rejection of a shipment of commingled commercial and industrial trash. The shipment was returned to the point of origin in Peabody, which was the Casella Waste Systems facility at 295 Forest Street. The load was secured at 295 Forest Street in Peabody until their competent consultant could survey and process the load on April 21, 2009. The consultant separated out over 150 industrial smoke detectors from the front end loader. These devices were industrial smoke detectors. Most models contained Am-241 80 micro curies each; but many others contained 40 micro curies each of Radium-226. The consultant faxed a preliminary report to the [MA state] Agency on April 22, 2009 and pledged to follow-up with an accurate breakdown of the exact RAM and total activities involved as the information is developed. Complete information was not available as of the time of this report. This same consultant is also arranging for the legal disposition of the smoke detectors and assisting the Casella Waste Systems management in tracking down the source of the RAM."

SOURCES LOST DURING SHIPMENT

Two Improved Chemical Agent Monitors (ICAMs) were lost during a shipment from ORNG [Oregon National Guard] to Guam National Guard. Each ICAM contains a sealed source containing 10 mCi of Ni-63. (SSDR NR-1129-D-103-S). The ICAMs were packaged by ORNG personnel in May, 2007. The missing ICAMs were reported missing to the licensee on 9 Feb 09. In the weeks following the notification, the licensee conducted an investigation to determine if the ICAMs were actually lost or misplaced within military control. The licensee believes the two ICAMs were lost during the transport between Andersen AFB and Guam National Guard between 15-17 Aug 2007.

THIS MATERIAL EVENT CONTAINS A "LESS THAN CAT 3" LEVEL OF RADIOACTIVE MATERIAL

Sources that are "Less than IAEA Category 3 sources," are either sources that are very unlikely to cause permanent injury to individuals or contain a very small amount of radioactive material that would not cause any permanent injury. Some of these sources, such as moisture density gauges or thickness gauges that are Category 4, the amount of unshielded radioactive material, if not safely managed or securely protected, could possibly - although it is unlikely - temporarily injure someone who handled it or were otherwise in contact with it, or who were close to it for a period of many weeks.

This source is not amongst those sources or devices identified by the IAEA Code of Conduct for the Safety & Security of Radioactive Sources to be of concern from a radiological standpoint. Therefore is it being categorized as a less than Category 3 source