Event Notification Report for October 27, 2005

POTENTIAL EXTREMETY DOSE IN EXCESS OF 250 RAD

At about 3 PM on 10/27/05 following industrial radiography at the Sunoco Refinery in Philadelphia, PA, a radiographer approached the front of the radiography camera to disassemble the guide tube from the camera body. The radiographer thought that he had fully retracted the source but noticed that the source was exposed during the disassembly. The source was a 21.8 curie Iridium 192 source.

The radiographer contacted the radiation safety officer after he realized he had been overexposed. The radiographer received a calculated dose to his extremities of between 330 and 360 Rad. The licensee stated that the individual's self indicating dosimeter was off scale. The individual's thermo-luminescent dosimeter will be sent for a whole body exposure reading. Whole body calculated dose was less than 5 Rem. The radiographer was being sent for medical treatment.

The licensee has removed the radiographer from his duties pending further investigation. The licensee will determine corrective actions and perform stand-down training for the employees in the Trainer, PA field office concerning the occurrence.

UNANALYZED CONDITION

"As part of an ongoing Appendix R assessment, it has been determined that Operator actions credited in the Fire Hazards Analysis (FHA) potentially would not be met in fire zones credited for post fire safe shutdown per 10 CFR 50 Appendix R. Specifically, the FHA credited the availability of two in plant operators to conduct two separate series of operator actions that are required to be performed simultaneously within the first 20 minutes. However, the site Fire Plan requires one of these in plant operators to respond to a plant fire as a Fire Brigade member. Since no barrier was put in place to compensate for the lack of the credited operator; this event is reportable as an unanalyzed condition that significantly degraded plant safety."

The licensee notified the NRC Resident Inspector.

* * * RETRACTION FROM BOB MURELL TO W. GOTT AT 1314 ON 12/19/05 * * *

"Further review has determined that adequate operator resources are and have been available to perform the required post fire safe shutdown actions. Therefore, this event is not an unanalyzed condition that significantly degrades plant safety and is being retracted."

The licensee notified the NRC Resident Inspector.

Notified R3DO (H. Peterson)

MATERIAL ACCOUNTABILITY DISCREPANCY AT PLANT HATCH

"This is a non-emergency Event Notification made in accordance with 10 CFR 20.2201(a)(1)(ii) to inform the NRC of a nuclear material accountability discrepancy amounting to, in the aggregate, a portion of a spent fuel rod used at Plant Hatch (HNP). In the process of reviewing records and physically verifying the contents of the spent fuel pool (SFP) as a part of activities associated with SNC's [Southern Nuclear Company] response to Bulletin 2005-01, SNC has identified discrepancies between fuel segments located in the SFP and segments indicated in plant records.

"The segments originated in the early 1980s during fuel reconstitution and inspection activities. The discrepancies call into question the location of segments of single spent fuel rods in each of three bundles. Characterization of three segments located in the SFP provided rod serial numbers which, in turn, were used to determine the bundles from which these segments originated. These bundles were then inspected, and the length of fuel in the location corresponding to each rod segment's intended location was determined. The aggregate in-bundle length found in these rod locations was combined with the lengths of the segments located in the SFP and compared to the design active fuel length of the three rods. This comparison results in a material discrepancy of approximately 55 inches, based on the length measurements. In addition to this discrepancy, historical records indicate two segments (totaling 13 inches of fuel length), which may not be within the inventory of segments identified to date in the SFP. When this amount is added to the length associated with the three rod locations, a discrepancy of approximately 68 inches results. When the planned supplemental inspection of select bundles and SFP locations is completed and photographs are evaluated to aid in the determination of special nuclear material present, this 68 inch estimate may increase or decrease.

"On June 16, 2005 SNC formed a team to identify and characterize material in the SFPs at Hatch in order to account for special nuclear material (SNM) at the level of detail requested by Bulletin 2005-01. A work scope was established and specialized resources were contracted to support the work activities. During the performance of these work activities, a number of items of interest were characterized as being either SNM or non-SNM items. On October 28, 2005, SNC submitted the interim status report to NRC.

"On November 4, 2005 the Hatch Plant Review Board (PRB) reviewed the SNM Issue Resolution Team's assessment of data produced by the records searches and physical cataloging of SNM in the SFPs. Based on that review, the PRB concurred that a discrepancy exists in material accounting for a portion of a spent fuel rod in each of three bundles and records, as noted above, which in the aggregate approximates 68 inches of fuel rod length. This length is equivalent to about 45% of the length of one intact fuel rod. Further physical examination of the SFP will include additional examination of SFP floor areas that have not been examined to date and selected fuel bundle inspections. The SFP floor areas are limited to a small number of locations that are under equipment or objects stored on the SFP floor. This expanded work scope is expected to be completed by December 15, 2005.

"Based on the nature of the fuel rod segments and radiation monitoring, a high degree of confidence exists that the segments are in a restricted area of the plant or otherwise under the control of a licensed facility such that the public health and safety has not been adversely affected. In addition, there is no evidence of theft or diversion.

"This notification satisfies the 30-day notification requirement of 10 CFR 20.2201(a)(1)(ii). A subsequent written report will be made in accordance with 10 CFR 20.2201(b).

"The licensee has informed the NRC Resident Inspector regarding the discrepancies.

"SNC will be making a press release describing the current status of this issue. Accordingly, this notification also satisfies the 4-hour notification requirement of 10 CFR 50.72(b)(2)(xi) with respect to issuance of the press release associated with this issue."

* * * UPDATE AT 15:48 ON 8/21/2006 FROM FRANK GORLEY TO ABRAMOVITZ * * *

"This is an update of non-emergency Event Notification 42135 that was previously made on November 10, 2005, in accordance with 10CFR 20.2201. This non-emergency Event Notification is made in accordance with 10 CFR 74.11 and informs the NRC of the loss of special nuclear material (SNM) from the historic breakage of several fuel rods used at Plant Hatch (HNP) in the early 1980s amounting to, in the aggregate, approximately 18 inches of a spent fuel rod. This amount is based on the available information, potentially affected by incomplete historic documentation. While reviewing records and physically verifying the contents of the spent fuel pool (SFP) in 2005 and 2006 associated with its response to Bulletin 2005-01, SNC identified discrepancies between fuel rod segments located in the SFP and segments indicated in plant records. This discrepancy was the subject of Event Notification 42135 and LER 2005-003 transmitted by letter NL-05-2262 dated 12/09/2005, including Rev. 1 of the LER, dated 04/14/2006 (transmitted by letter NL-06-0689).

"Additional locations in and around the fuel racks and additional fuel bundles were inspected between November 11, 2005, and July 21, 2006. Fuel vendor disorientation and plant SNM offsite shipping records reviews and quantity reconciliations were also recently completed. Based an the results of this expanded work scope, SNC concluded that some SNM material has been lost. This material either resides in some unidentified location in the SFP, resides in the bottom of the SFP as particles or small pieces, or was inadvertently shipped to a licensed low level waste processing facility.

"One SNM fragment, referred to as Item 30, was dropped during the physical activities in the pools and has not yet been recovered. This 4-1/2-inch fuel segment had been characterized and quantified and was dropped in the SFP during handling. A search was performed to look for item 30, but the intact segment was not found. During this search, a cladding segment with no appreciable SNM inside was located and identified as Item 32. It may be a portion of Item 30. Item 30's fuel length of 4-1/2 inches is included in the total characterized as lost.

"Based on the nature of the fuel rod segments, fragments, pellets, pellet chips, and small particles, and the barrier provided by in-plant radiation monitoring Instrumentation, a high degree of confidence exists that the lost SNM is either still in the SFP or was inadvertently shipped offsite to a licensed low level waste processing facility. Throughout its investigation and review, SNC has identified no evidence to indicate the possibility of theft or diversion of the missing quantity of SNM material.

"This notification satisfies the one-hour notification requirement of 10 CFR 74.11 (b). A subsequent written report will be made in accordance with 10CFR74.11(c). The licensee has informed the NRC Resident Inspector regarding the discrepancies and the conclusion regarding the lost material. SNC will be making a press release describing the current status of this issue. Accordingly, this notification also satisfies the 4-hour notification requirement of 10 CFR 50.72(b)(2)(xi) with respect to issuance of the press release associated with this issue."

Notified the R2DO (Lesser), PAO (Brenner), and NRR EO (Jung).