Event Notification Report for November 12, 2009

VIOLATION OF A NUCLEAR CRITICALITY SAFETY CONTROL

"At 1115 CST on 11/12/09, abandoned cell piping was reported in C-331 and C-335 cell housings. The 16-inch abandoned piping is from the cell recycle line that was replaced in the mid 1970s. NCS [Nuclear Criticality Safety] controls require that equipment openings with unknown uranium deposits shall be covered with water-proof covers that are fire resistant. Since the piping contains an unknown uranium mass, and was discovered without water-proof covers, the NCS control was violated.

"Since moderation is the primary criticality control, and where double contingency cannot be re-established within 4 hours, this is being reported to the NRC as a 4-hour Event Report in accordance with NRC BL 91-01 Supplement 1.

"The NRC Resident Inspector has been notified of this event.

"PGDP Problem Report No. ATRC-09-2781; PGDP Event Report No. PAD-2009-19.

"Safety significance of events: Although the NCS control to cover the pipe openings was violated, it was not exposed to a liquid moderator. The geometry of the pipe is safe for a maximum enrichment that may be in the pipe. During the plant modifications that replaced the cell recycle lines, the maximum plant enrichment was 2.0 wt. % U235. There are no indications, based on quarterly NDA scans, that the piping contains greater than a safe mass of uranium. Therefore, the safety significance of the event is low.

"Potential criticality pathways involved: The maximum plant enrichment at the time the piping was in operation was a maximum 2.0 wt. % U235. The piping is contained in housing without fire suppression. The single parameter pipe diameter for that enrichment is greater than 16 inches. In order for a criticality to be possible, the pipe would have to contain greater than a critical mass. A large amount of moderator would have to enter the horizontal pipe opening. Greater than a critical mass would then have to be washed from the pipe due to the unlikely moderator release at the pipe opening. The washed material would then have to accumulate in an unsafe geometry.

"Controlled parameters: Moderation.

"Estimated amount, enrichment, form of licensed material: The assay of any material is less than or equal to 2.00 wt. % U235.

"Nuclear Criticality safety control(s) or control systems(s) and description of the failures or deficiencies: The first leg of double contingency relies on control of moderation. Moderator intrusion associated with sprinkler activation is controlled by limiting fire sprinkler head activation temperatures at the ceiling and bypass heights. The analysis also determined that significant moderator intrusion into open fissile piping due to inadvertent spills, RCW/oil line leaks, or other mechanism is unlikely. These controls were not violated and an unlikely moderator release event has not occurred at the pipe opening. The second leg of double contingency is also based on moderation. Piping exceeding 10.25 inches that contains an unknown or greater than safe mass deposit is required to have openings covered with fire resistant waterproof covers. Since the piping is nominal 16 inches in diameter, contains an unknown uranium mass, the NCS control was violated. Since the openings are not covered resulting in a loss of NCS control and there are two controls on one parameter, the process condition was not maintained.

"Corrective actions to restore safety systems and when each was implemented: Control access to the area. Exempt the pipe from NCS controls based on enrichment determination, cover the pipe openings, or quantify the uranium mass in the pipe."

NOTIFICATION TO US COAST GUARD AND COMMONWEALTH OF VIRGINIA OF HAZARD TO NAVIGATION

"Surry Power Station maintenance activities at the James River intake structure were supported with a barge from Crofton Industries using stop logs (referred to as caissons, each with dimensions of 24'x6'x3'and weighing 11,000 pounds empty) to seal water ingress into intake bays. On November 12, 2009, due to the potential for damage from high winds and tide, the barge and four of the caissons were towed by tug boat from the intake structure, across the James River, to Fort Eustis. At 1650 hours, mid-way across the river, one of the caissons broke free from the tug. The tug operator attempted to secure the partially submerged caisson, but was unsuccessful. The tug operator noted the location and completed the transfer of the barge and caissons to Fort Eustis.

"At approximately 1900 hours, Crofton Industries informed Surry Power Station that in accordance with the Marine Safety Office Notification Procedure, they communicated with the US Coast Guard, notifying them of the incident and the approximate location of the caisson. In addition, at 2030 hours, Surry made a courtesy notification of the incident to the Virginia Department of Emergency Services. This report is being submitted due to the notification of other government agencies under 10CFR50.72(b)(2)(xi). In addition, the Site NRC Resident was also notified of this event."

HPCI INOPERABLE DUE TO EXCESSIVE WATER IN STEAM DRAIN

"The HPCI [High Pressure Coolant Injection] system was declared inoperable after completion of a scheduled surveillance due to an excessive amount of water in the turbine exhaust line. The line was being drained in response to the alarm 'HPCI TURB EXH DRAIN POT LEVEL HIGH', indicating that there was a high level in a drain pot attached to the turbine exhaust line. An investigation is in progress to determine the source of the water in the turbine exhaust line.

"This event is reportable within 8 hours in accordance with 10CFR 50.72(b)(3)(v) as an event or condition that at the time of discovery could have prevented the fulfillment of a safety function. It also requires a 60 day written report in accordance with 10CFR 50.73(a)(2)(vii)

"The NRC Resident Inspector has been notified.

"SR number associated with this report: 91546."

FAILURE TO FULLY RETRACT THE SOURCE OF A RADIOGRAPHY CAMERA

Technicians were performing radiography at the Kuparuk Oil Field in Prudhoe Bay, Alaska when the source in an Industrial Nuclear Corporation (INC) IR-100 radiography camera, serial number 6643 was unable to be fully retracted. This was caused by a frozen lock on the device which occurred due to weather conditions of blowing snow and freezing rain. A certified technician serviced the lock. The lock was returned to fully functional condition and the source was returned to the safe and secure position. The device has a 101 Ci Ir-192 source. No personnel over exposures occurred.

AGREEMENT STATE REPORT - PERSONNEL OVEREXPOSURE DURING RADIOGRAPHY

The following report was received via facsimile:

"On November 13, 2009 the RSO [Radiation Safety Officer] for Owensby & Kritikos (O & K), contacted LDEQ [Louisiana Department of Environmental Quality] to report an excessive exposure. O & K had a radiography crew x-raying a pressure vessel. The radiographers believed that they had cranked the source in the camera. One of the radiographers went to the camera without a survey meter to remove the source guide tube. He was trying to put the safety plug on the end of the camera, but it would not go on. At this point, he realized that the source was not in the shielded position. Instead of roping off the area and calling the RSO per their procedures, they got the source in the shielded position themselves. This occurred on November 12, 2009 and the radiographers did not tell the RSO until November 13, 2009. Both of the pocket dosimeters were off scale. The radiographers said they where wearing their rate alarm meters. The personnel monitors were sent to Landauer for emergency processing. One of the radiographers had a dose of 5.57 rem for November with a year dose of 6.67 rem. The other radiographer had a November dose of 0.45 rem and a year dose of 1.00 rem. At this time, LDEQ believes these exposures to be true exposures to the radiographers. The crew had an AEA 660B camera, s/n B1495, that had a 79 Ci Ir-192 source, s/n 57338B. The last leak test was on October 12, 2009. LDEQ has begun an investigation and will report any new information.

AGREEMENT STATE REPORT - FIXED GAUGE EXPOSURE INCIDENT

The following information was received via E-mail:

"On November 12, 2009, two Public Service Company of Colorado (PSCo) employees removed a fixed gauge (including the source and detector) that was mounted on a pipe to measure scrubber slurry flow. The detector was not working correctly and needed to be repaired. During the process, the employees left the shutter on the source open and received a radiation exposure. Removing the source from the pipe and leaving the shutter open are not allowed by company procedures or the radioactive materials license.

"The Colorado Department of Public Health and Environment (CDPHE) was contacted about the November 12, 2009 incident by the PSCo Radiation Safety Officer (RSO) on November 12, 2009. At the time CDPHE was contacted it was believed that the shutter had been closed during the work and that there was no unplanned employee exposure. CDPHE was informed that PSCo employees would perform no further work on the source holder and that it was secured at the location where it was taken down. Also, any further work to reinstall the source would be performed by an NRC certified entity. Public Service Company of Colorado (License #032-01) is a specific licensee of the State of Colorado Agreement State Program.

"On January 29, 2010 while talking to the instrument and control technician employees that had performed the (November 12, 2009) gauge removal, the PSCo RSO learned that the shutter had in fact been open during the work, and the shutter was locked after the source was taken down from its operating location. This was the first time the employee working on the gauge had informed anyone about the shutter being open while the employees removed the detector. On the afternoon of January 29, 2010 the PSCo RSO notified CDPHE via email to provide initial notification of the potential radiation exposure incident.

"On February 4, 2010 the RSO for PSCo submitted additional information to CDPHE regarding the incident including exposure estimates for the employees involved. The licensee estimated that employee #1 received an exposure of approximately 25 mrem, while employee #2 received an exposure of approximately 0.9 mrem.

"The gauge involved in the incident was an Ohmart model SR-A, Source Holder Serial #2690CG, containing approximately 50 mCi (1.85 GBq) of Cs-137 (source mfg date is April 2002). The gauge was originally installed in the licensee's facility in October, 2002.

"The Colorado Department of Public Health and Environment has assigned incident number I10-02 to this incident and is continuing to investigate. The licensee (PSCo) has started an incident investigation to evaluate the incident and determine appropriate corrective actions."