IR 05000010/1982008
| ML20058E003 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/07/1982 |
| From: | Greger L, Peck C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058D981 | List: |
| References | |
| 50-010-82-08, 50-10-82-8, 50-237-82-12, 50-249-82-13, NUDOCS 8207270464 | |
| Download: ML20058E003 (6) | |
Text
{{#Wiki_filter:. . . U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-10/82-08(DETP); 50-237/82-12(DETP); 50-249/82-13(DETP) Docket Nos. 50-10; 50-237; 50-249 Licenses No. DPR-02; DPR-19; DPR-25 Licensee: Commonwealth Edison Company Post Office Box 767 chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2 and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted: June 16, 17, 21 and 25, 1982 hh [[ 7!7 2.
Inspector: C. C. Peck 7!7!SS Approved By: L. R. Grege e Facilities Radiation Protection Section Inspection Summary Inspection on June 16, 17, 21, and 25, 1982 (Reports No. 50-10/82-08(DETP); 50-237/82-12(DETP); 50-249/82-13(DETP)) Areas Inspected: Routine, unannounced inspection of transportation activities including: packaging, preparation of shipments, shipping papers, audits, and training. The inspection required 18 hours by one NRC inspector.
Results: No violations were identified.
8207270464 820709 PDR ADOCK 05000010 G PDR
. . . DETAILS 1.
Persons Contacted
- D.
Scott, Station Superintendent
- G. Myrick, Radiation Chemistry Supervisor T. Gilman, Lead Health Physicist
- D. Sharper, Radwaste Supervisor T. Palanyk, Radwaste Engineer B. Zank, Training Supervisor L. McCoy, Training Instructor R. Stobert, Quality Assurance Lead Inspector
- M. Jordan, NRC Resident Inspector
- R. Paul, NRC Radiation Specialist The inspector also talked with radwaste foremen and operators, radiation chemistry technicians, and quality assurance inspectors.
- Indicates those present at exit interview.
In addition, L. R. Greger from NRC Region III attended the exit interview.
2.
General This routine unannounced inspection was conducted to determine the licensee's compliance with packaging and transportation requirements of the NRC, the DOT, and commercial waste burial sites licensed by agreement states. The inspection began at 9:00 a.m. on June 16 and an exit interview was conducted on June 25, 1982.
3.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-010/80-18, 50-237/80-20, 50-249/80-24).
The lid of a metal bin containing LSA waste was found to be unsecured when the bin was inspected on arrival at a waste burial site. Examination of the applicable waste packaging and inspection procedures disclosed that the licensee made appropriate procedural changes to prevent recurrence.
(Closed) Commitment (50-010/79-23, 50-237/79-27, 50-249/79-25).
Retraining programs in the regulatory requirements for low level waste packaging and transport and in packaging requirements for waste solidi-fication system operators had not been established.
Discussions with Training Department and Quality Assurance personnel and examination of training records indicated that retraining programs have been implemented.
(Closed) Noncompliance (50-010/79-23, 50-237/79-27, 50-249/79-25). The Radioactive Material Shipment Record (RSR) required by procedure to be prepared and to accompany each radwaste shipment was not in use.
An examination of shipping papers disclosed that the RSR is now being routinely used.
-- -.
. 4.
Transportation Activities Shipments of low specific activity (LSA) waste to licensed burial sites are the major transporation activity. Contaminated solid trash (paper, plastic, wood, metal, discarded clothing, etc.) is packaged in 55-gallon steel drums and compacted, or in large metal boxes if the materials are not compactable. New DOT Specification 17-H drums are used which meet the DDT 7-A performance specification. The metal boxes are supplied by a vendor and have replaced the wooden boxes formerly used.
Liquid wastes consisting of resins, filter sludge, and evaporator bottoms are solidified using a Stock Equipment Company cement solidification system.
Programmed amounts of waste and cement are added to Specification 17-C drums through a bunghole in the non-removable top of the drum. After the drum is tumbled, more waste and cement are added and the drum tumbled a second time to promote uniform mixing and solidification.
Following the solidification process, measurements are made to determine drum radiation levels, curie content, and contamination levels. The entire process and subsequent storage and loading into exclusive-use transport vehicles is accomplished remotely.
The inspector observed the preparation of a shipment of metal boxes and drums. Operating procedures and checksheets were used to ensure compliance with regulatory and burial site requirements pertaining to packaging and marking, vehicle loading, radiation level, and placarding.
Shipping papers were complete. The waste solidification system was not operated during the inspection, nor was a shipment of solidified waste prepared. Such shipments require the use of 9 shielded cask, and the vehicle loading area becomes a high radiation area. High radiation signs are available at each of the several doors through which an individual might inadvertently enter the area, and the doors can be secured. From discussions with licensee representatives and examina-tion of operating and quality assurance procedures, the inspector concluded that controls and procedures were adequate to minimize employee exposures and to achieve compliance with DOT, NRC, and burial site requirements.
Other transportation activities include the occasional receipt of new fuel and of miscellaneous radioactive materials.
Radioactive materials and contaminated tools and equipment are sometimes received from and shipped to the utility's other nuclear stations in exclusive use company vehicles. Licensee procedures for meeting the regulatory requirements for these transfers are adequate.
The recent receipt of a Type A quantity of radioactive xenon gas from Canada (AECL) was discussed during the inspection and at the exit in-terview. The gas, contained in an inner ampule at atmospheric pressure, was packaged in a 5 gallon steel can marked " Type A."
The licensee's receipt survey disclosed higher radiation 1cvels than were indicated on I the Yellow II labels affixed to the can.
The licensee replaced these I labels with Yellow III labels, prepared shipping papers, and trans-l shipped the can by company-owned exclusive use vehicle to another of the utility's stations without determining the cause of the high radiation levels. When the 5 gallon can was opened the xenon gas ! l '
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escaped due to leakage of the gas from the inner to the outer con-tainer. This leakage had been the cause of the high radiation levels measured in the licensee's receipt survey.
In this instance, the shipment of a defective package by the licensee did not violate any DOT regulation because 49 CFR 173.395(a)(4) permits the shipment of foreign-made packagings bearing the marking " Type A" without verifying i that the packaging meets the performance test criteria of DDT Specifi-L cation 7A.
The packaging had apparently not been subjected to I Specification 7A test conditions for a gaseous content by the original shipper.
It was pointed out to the licensee that all shippers of a " Type A" quantity of radioactive material are normally required by DOT Regulations to have cercification that the packaging used meets , Specification 7A test criteria. Testing and certification may be performed by either the shipper or other competent person.
Company vehicles are sometimes used to transport radioactively con-taminated equipment and materials from one nuclear station to another.
These are exclusive-use shipments. Contamination was detected on interior vehicle surfaces on more than one occasion when shipments from the licensee reached another station. There is no evidence that the contamination was caused by leaking packages.
Licensee representa-tives agreed to investigate the matter, although the contamination found did not exceed NRC or DOT limits.
5.
Procedures The listed quality assurance, radiation-chemistry, and operating pro-cedures related to the preparation and transportation of radioactive materials were reviewed. The procedures adequately assign respon-sibilities and are consistent with DOT, NRC, and burial site requirements.
Number Procedure Revision I ' QP13-52 Preparation and Shipment of
Radioactive Materials i i DRP1520-2 Curie Content of Radioactive
l Shipments (Common Containers) i i DRP1520-3 Curie Content of Radioactive
l Shipments (Non-routine Containers) l l DRP1520-4 Shipment of Wooden Boxes
(Procedure no longer used) i j DRP1520-5 Receipt of Radioactive Material
l Shipments DRP1520-6 Surveying Radioactive Shipments
! DRP1520-7 Operation of Stock System Labeling Station
l I
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, . .e , . F . Number Procedure Revision DRP1520-8 Survey of DAW Drums and. Poxes
DRP1520-9 Operation of Stock Systen Proportional C Counter DRP1520-1 Offsite Shipment of Radioactive
Materials (Incorporated into training program) D0P2000-38 Drum Labeling and Inspection
Station Operation DOP2000-39 Loading of Radwaste Shipments
D0P2000-40 Inspection of Radwaste Shipments
DOP2000-42 Packing and Preparation of Metal
DAW Boxes DOP2000-22 Operation of Waste Compactor
DOP2000-32 Sludge Pump Operation to Decant Tank
DOP2000-33 Spent Resin Pump Operation to Decant Tank
DOP2000-34 Waste Transfer to Drumming Station
D0P2000-35 Decant Station Operation
DOP2000-36 Drumming Station Operation
D0P2000-37 Cement Fill Station Operation
l QA Radwaste Shipment Checklist'
- i s l 6.
Training l The licensee established a training program in 1979 for employees
i involved in radioactive waste packaging and shipment.. The inspector reviewed individual training records and a training outline indicating ' ! that operating shifts were retrained in early 1981. Subjects included I DOT and NRC regulations, burial site requirements, quality assurance procedures, station operating procedures, radiation protection pro-cedures, and waste volume reduction. The licensee plans retraining at two year intervals.
, l 7.
Audits e ! i Quality Assurance inspectors complete a checklist for each radwaste shipment prepared. Condition of the vehicle, cask, drums, boxes, and completeness of shipping papers are verified.
Inspectors are trained l I '
i l' - _ _ _ _ _ _,. _ _ _ _ -. - _ -. _. _, . -. - _ _ _ __. _.. _, _ _ _ _. -.. _....,. ,
T .... . , . . b in regulatory and burial site requirements and receive on'-the-job training before they inspect shipments independently.
> Records of the annual radwaste audit performed by the lead Quality Assurance inspector in 1981 were examined. The audit verified that training was conducted or planned and that packaging and shipments were being accomplished in accordance with approved procedures.
The licensee's cement system apparently solidifies liquids reliably, based on experience, routine observation of the top of the mix through the open bung, and occasional inspections of some drums-that were opened to verify that they contained no free standing liquid. A drum was penetrated during a previous inspection,(Reports No. 50-010/79-23, 50-237/79-27, 50-249/79-25), and drums were' punctured by the Radwaste Supervisor in 1981. However, the system does not afford the opportunity for visual observation of the solid mass after solidification.
In dis- ' cussions during the inspection and at the exit interview, the licensee agreed to make destructive penetratiores of drums periodically to verify completeness of solidification.
8.
Exit Interview The inspector summarized the scope and findings of the inspection at an exit meeting with the licensee representatives identified in Section 1 on June 25, 1982. The licensee representatives acknowledged the inspector's comments concerning: a.
The DOT requirement that the shipper have certification that the packagings used for " Type A" quantities of radioactive miterial meet Specification 7-A (Section 4).
b.
The possible problem of contaminated company vehicles (Section 4).
c.
Periodic, documented, visual inspections of the solidified mix in 55 gallon drums (Section 7).
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