IR 05000133/1981003
| ML20010E906 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 08/10/1981 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20010E904 | List: |
| References | |
| 50-133-81-03, 50-133-81-3, NUDOCS 8109090087 | |
| Download: ML20010E906 (11) | |
Text
.
.
. U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
50-133/81-03 Docicet No.
50-133 License No.
DPR-7 Safeguards Group
'
' Pacific' Gas and Electric Company Licensee:
~
77 Beale Street
.
San Francisco, California 94106
,
Facility Name:
Humboldt Bay Unit 3 Inspection at:
Eureka, California
'.r.spection conducted:
June 29 - July 2,1981 Inspectors:
ubo D 7-Rl G. P.
as, Radiation Specialist Date Signed
!
Date Signed k
Vf7/8/
'
a na Approved by:
F. A' Wenslaws
, Chi f, Reactor Radiation Protection tat'e Signed
/O
/
-
Approved By:
.
,
- Date ' Signed H. E. Book, Chief, Radiological Safety Branch
'
Summary:
Inspection on June 29-July 2, 1981 (Report No. 50-133/81-03)
-
Areas Inspected: Routine unannounced inspection by a regional based inspector of the radioactive waste systems'during the extended shutdown, activities
!
associated with the packaging and shipment of radioactive materials, and review of the licensee's response to IE Bulletin 81-07. The inspector also observed an Emergency Plan Drill conducted on June 30, 1981. The inspection involved 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> onsite by one NRC inspector.
Results: Of the four areas inspected, one item of noncompliance was identified:
,
failure to set the liquid waste system vent monitor consistent with Technical
Specification VII. B. 4,(Paragraph 5).
.
l RV Form 219 (2)
81@9090087 810811
'PDR ADOCK 0D000133'
~@
_
__
_
_
/,
y
.
,
.
,
g DETAILS:
>
,
,O
'
'
1.
Persons Contacted
,-
i t.
.
E.. Weeks, Plant Superintendent i '.s t
.
- D. Voss, Supervisor, of 0perations ji j s. i
~
'
-
,
R. flelson, Power Plant Engineer ' >
.
- R. Parker, Senior Chemistrnand Radiation' Protection Engineer
- B. Getty, Senior Power Production Engineer'
- D. Peterson, Quality Control,Supervis,or,
R. Lund, Radiation Protection Foreman '
.
H. Darington, Instrumentiand. Control Supervisor
.H. Connerly, Radiation and Process Monitor,
,
- Denotes those individuals a_ttending the exit interview on July 2,1981.
2.
Licensee Response to IE' Bulletins and Circulars a.
IE Circular 81-07, " Control of Radioactively Contaminated Material" was received by the licensee on fiay 20, 1981. As of this inspection, the licensee had not completed their review of this circular.
The inspector reviewed Radiation Control Procedure No. 6A, " Release of Materials from Controlled Areas",
Revision 25, dated September 1977.
This procedure addresses the same topics covered in IE Circular 81-07. With exception of Table 1, " Surface Contamination Limits" the procedure is consistent with the circular. During tours of the controlled area the inspector observed that standard aluminum. foil had been placed over the thin window Gieger Mueller detectors used to make release surveys.
The inspector discussed the decreased efficiency resulting from attenuation by the aluminum foil with licensee representatives.
The Senior Chemistry and Radiation Protection Engineer stated that the foil would be removed from the detectors.
Guidance provided in the circular will be incorporated in the scheduled revision of RCP No. 6A according to the licensee representative.
The inspector had no further questions regarding this matter.
b.
IE Bulletin 80-10. " Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release to Environment."
The licensee's response was reviewed during the December 1980 inspection (Inspection Report No. 50-133/80-04).
Since that inspection the licensee has sampled the instrument air system and calculated the activities of other samples collected pursuant to procedure RCP A-1, " Chemical and Radiochemical Control Program".
The yard drain system has not been included in the procedure or sampled as yet.
Review of April 1981 sample result 3 indicated contamination in the cassion sump, spent fuel pool liner, french drains, instrument air, Well No. 3, and Unit 1, 2 boilers.
Contamination was not expected in the instrument air or the Units 1 and 2 boilers.
The licensee had
'
not resolved the activities reported for these systems.
The
<
--
-2-
.
'
licensee had analyzed the samples on their new intrinsic germanium gamma counting system. Review of the counting data cast some doubt on whether the boilers samples were truly
contaminated with cesium 137 and cobalt 60. Accordingly, samples of Unit 1 and 2 boilers and Well No. 3 were collected, acidified and split for analysis by NRC and the licensee. Additionally, the instrument air sample collected and counted by the licensee was given to NRC for independent analysis.
The four samples were analyzed at the NRC's Region V mobile Laboratory using an intrinsic germanium detector. The resu15.s are summarized in table 1.
~ TABLE I
'
,
-
,
m.
s.
.
,
'
'
~
'
<
,
,
,
<
.
Appendix B
- - '
- ~'
"
Isotopes : observed
.
Counting Table II
-
Sample Other than Naturally.'
. Activi ty -
, Error in Values in Description Occuring Radioactivity uC1/ml ~ "
' Percent uCi/ml
-
-
~
+
.
,.
>.
.
Instrument Air 137 Cs 8.06E-13 24.7 SE-10'
-
goo;Demineralizer,
.
60 Co-1.81 E-12
-
19.8 3E-10 t
'
a
.,
,
Sample Well 1157Cs 1.49E-7 5.22 2E-5 No. 3
'60 Co 2.60E-7 4.25 3E-5
Unit 1 Boiler LLD*
Water None (137 Cs.=.5E-9 2E-5-( 60 Co = SE-9 3E-5 Unit 2 Boiler LLD*
Water None (137 Cs = 1E-8 2E-5 ( 60 Co = 1E-8 3E 5
- LLD the lower limit of detection.
.
t
' t
-
_
- 3-
.
'
On July 13, 1981 the licensee representative was notified by telephone of the results of NRC analysis as noted sbove. Although the activity observed in the instrument air system and sample Well No. 3 are significantly less than the 10 CFR 20 limit further evaluation by
,
the licensee is appropriate.
The licensee's response to IE Bulletin 80-10 is considered incomplete and will be reviewed in a subsequent inspection.
3.
Emergency Plan Drill On June 30,1981 at 2:00 PM the itcaasee conducted a drill as reqJired in Section VI.C. of the Emergency han. The drill was supervised by l
the Senior Power Production Engineer and observed by the Quality Control Supervisor. The-drill senario included an earthquake causing collapse of the stack onto the fuel handlirig building and damage to the spent fuel storage pool.
The inspector observed the licensee's actions from the control room.
The licensee's actions were appropriate and consistent with the emergency plan implementing procedures.. Immediately following the drill the inspector observed the discussion and evaluation of the
,
'
drill by the principal participants and-the observers.
The critique was l
meaningful and can result in improved licensee performance.
l No items of noncompli3nce were identified.
-
-,
cw
,
4.
Transportation Activitih s-
-
,
a.
Management Controls
- '
Radiation Control Stand'ard No." 67 " Control of Railioactive
~
,
l Materials" Revision 6,. reviewed by. the PSRC on November 6, 1980
!
establishes policy;for;onsiteecor. trol,ireceipt' and sh'ipment of
.
radioactive' materials.' ' Radiation C6ntrol Procedure 6C, (RCS6C)
l
" Radioactive Material' Shipments", Rev_ision 40 andiRCS6B, j
" Construction, Testing and Certification' of ". Type. A" Shipping
!
Containers", Revision 37 provide the basic technical guidance l
necessary to package and ' ship radioactive materials.
Duties
'
and responsibilities in this area.are as previously described in Inspecti,n Report No. 50-133/80-01.
During 1980 the licensee l
solidified significant quantities of liquid radioactive wastes l
for shipment in NRC certified casks.. Procedure D-250, " General
'
Requirements for Solidification.of Wet Radioactive Waste" and a series of-nine temporary procedures were established reviewed and approved to insure the process complied with the requirements expressed in 10 CFR 71. The inspector reviewed the following j
procedures.
r-
~
q
.
- Temporary
.
Procedure i
s
,
,
l No.
Revision Title
'
"
- ;
_
.. _.
..
8/26/80 #1.
, 70-8/80i, Disposal, Project-Organization of t'
'.
- iy
, Responsibility x
,
,
c
.
.
18/26/80 #2
'7d-8/80'
u Program for Solidification of Wet i
.' ' Radioactive Waste Using the CNSI Portable
^'
i
' ',
,
- Solidification System
~
f 8/26/80T#3 [
771-9/80l 7 nspection of Spill Containment Provisions I
'
8/26/80'#4 73-11/80'
' Solid fication System CNSI Op. Proc.
SD.0P-013
-
8/26/80 #5 70-8/80 10ualit Plan - General
8/26/80 #6 70-8/80 Equipment / System Design Package 8/26/80 #7 72-10/80 Cask Handling for Resin or Concentrated Liquid Waste Disposal i.
'
8/26/80 #8 72 10-80 Waste Transfer for Evaporator Bottoms 9/29/80 71-9/80 Dewatering Solidification Liner No. 25722-11 In 1981 the licensee made a considerable effort to dispose of the accumdlation of dry radioactive waste stored onsite.
To minimize the volume of material to be shipped and buried the licensee procured
.
a Stock Equipment Company dry wa;te compactor.
This device compresses l
-
material into 55 gallon drums.
Three procedures were estalbished to j
accomplish this activity.
These procedures were also reviewed by the l
inspector, i
l Procedure No.
Ti tle l
F-8 Soil Waste Compaction l
TP 5/6/81 Repackaging of Radwaste Containers TP 5/21/81 Compaction of Solid Radioactive Waste
,
l l
The procedures noted above have been developed consistent with i
Technical Specifications and regulatory requirements.
!
!
No changes in the radwaste training program have been made since the last inspection.
Training records indicate that a one hour session on the solidification program was conducted 'on August 29, 1980 by the Senior Chemistry and Radiation Protection Engineer.
This course was attended by the technicians involved in the l
task.
The Senior Chemistry and Radiation Protection Engineer i
attended a one week seminar in February 1981 on radwaste volume reduction, and solidification sponsored by the Electric Power Research Institute.
The Quality Control Supervicor attended a four day seminar in May 1981, on radwaste transporation activities
.
presented by Nuclear Energy Waste Management Consultants.
On return
,
from this seminar the QC Supervisor conducted a training session for the licensee staff on material presented at the seminar.
.
,-
~
- -
y
_
-6-
.
.
- Audits of the radioactive material packaging and shipping program are conducted in accordance with the licensees, " Quality
- Assurance Manual _ for Operating Nuclear Power Plants".
Tne inspector reviewed Audit Report No. 01091 performed by representatives of the corporate Quality Assurance Department on October 1-3, 1980.
The audit focused an. review of the solidification program in progress at that. time. <Two problem areas were identified and Problem ReportsLis~ sued (HB3-80-QC-0927/QA0T 051-80 failure to review RCP 6A, HB3-80-QC-0928/QA 01 052-80 failure of the solidification vendor to perform onsite insopction as called foriin TIP 8/26/80 #2).
The inspectre rev ewed' records that indicated that the solidification vr idor was notified and two audits were performed by vendor epresentatives on October 13, 14 and October 22,1980." The inspections involved 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> on site by the vendor representative.
i
s
,
^
,
'In~ sddition to the Quality Assurance; Audit, Quality Control audits are p6rformed more;freauently. _Each shipment of radioactive materials is audited by the Q.C. Supervisor. " j
<
.
-,
-
.
At this tim'e:the licensee's: management control-program does not specifically: address packaging and^ shipment of irradiated spent fuel or daintenance._of+ licensed shi In the period of review March 1980 - July'pping containers.
~
1981 the licensee representatives stated, that no fuel had been shipphd and no maintenance' had been performed on-NRC certified casks.
'
s No items of noncompliance were ' identified in this area.
b.
Implementation (1) Solidification The purpose of the licensee's solidification program was to dispose of _ the ten year accumulation of regenerate solution stored in the Waste Concentrate Tanks.
The inspector verified by record review that the licensee
.
had sampled and analyzed the radioactive contents of the tanks.
In addition to the inhouse analysis the licensee sent a sample to an independent laboratory (LFE,. Enviornmental Analysis Laboratory) for analysis.
This information was used to develop the isotopic and curie content for each shipment.
The licensee contracted with Chem-Nuclear Systems,. Inc. to solidify the waste using.an urea formaldeyde process.
The concentrate-was solidified in liners, shipped in a CNSI 21-300 cask to the U.S. Ecology's Washington State burial facility.
>
g
-
e
.
-
>
e w.
~
v
,
,
,
e
- -
_
-6-
.
The inspector verified that the licensee had in their possession a copy of the burial license UN 1019-2 thru Amendment 14 to comply with 10 CFR 30.41.
The licensee had registered as~ a user of the CNSI 21-300 cask in a letter dated August 12, 1980.
The licensee also had a copy of NRC Certificate of Compliance 9096, Revision 3 and the documents and drawings referenced therein as required pursuant to_10 CFR 71.12.
,
use of the urei'formaldeyde process was complicated by the chemical constituents 'of the regenerative concentrata according to the licensee representative.
Of nine batches processed, in only one instance did the licansee feel comfortable that Condition 27 (free standing liquid) of WN1019-2 had been satisfied by merely following the process control program.
In the other eight cases additional measures were necessary to ass'ure. th'emselves -that the process had been satisfactorily completed.
The inspector verified that the licensee had onsite an up to date copy of 10 CFR 71 and information letters dated May 29, and September 17, 1980 from the PG&E corporate Materials Departuent advising Humboldt Bay Unit 3 of changes in the transporation regulations (49 CFR 100-199).
No items of noncompliance were identified.
(2) Preparation of Packages for Shipment During tours of the controlled areas on June 29 and July 1, 1981 the inspector observed a major reduction in the amount of solid radioactive waste in storage.
The inspector selected two packages which had been prepared for shipment for detailed inspection.
One 55 gallon drum identified
'
as No.81-163 was marked as 17H and labeled " Radioactive LSA".
The drum had no dents, creases or other indications of deterioration.
The drum weight (320#) was marked and the licensee's survey tag indicated radiation levels of 50 mr/hr at two inches and 5 mr/hr at three feet from the drum surface.
The inspector resurveyed the drum using a portable ionization chamber NRC Property No. 009154 i
due for calibration on August 12, 1981.
The licensee representative al!.o resurveyed the drum using a similar instrument.
The results are noted below.
-
-
G
k-7 '
.
..
CONTAINER NO.81-163 Dose Rate 'at 2" '
Dose Rate at 3'
Licensee 60 mr/hr 2.7 mr/hr
'NRC 60 mr/hr 2.2 mr/hr The drum lid was removed. The closure ring, lip, and' gasket were in good condition.
The drum was laid on it's side for.about five minutes and no evidence of frae standing liquid was observed.
A 4'X4'X4' wood box identified as No.81-219 was labeled " Radioactive LSA" and Dore a survey tag indicating a dose rate of 13 mr/hr at two inches and 2 mr/hr at three feet.
The inspector surveyed the bor. and measured 15 mr/hr at two inches and 2.5 mr/hr at three feet using the portable ionization damber.. cThe box was made of wax inpregnated plywood, joirits were sealed with silcone caulking.
The box was banded andisecurely attached to a pallet.
,,,
_
~
.
-
No items of noncompliance'were identified in this area.
(3) RecordsofDeliviry'cf'Completedjacka'aes'to' Carriers The inspector revkewed. documentation maintained.by the licensee of, shipments made in, the period May-1980 thru June 1981. Seven rec'ord packages were given detailed i
review to determine cmplianch with'the_licensce's procedures and regulatory requirements expres' sed in 10 CFR 30.41,10 CFR 71, and 49 CFR 172 and;173 ' Two shipments, identified by the
licensee as Shipment Nos. 327 and 328 involving radioactive samp'es; two involving boxes-and drums, shipment Nos. 341, 342; and three involving solidified waste concentrates, Shipments
!
Nos. 329, 331 and 333 were reviewed.
The following applicable records were reviewed for each shipment.
. PGE, Radioactive Material ' Shipment 'Remord
. Straight Bill of Lading
.
"
. Washington State Certification
. U.S. Ecology, Radwaste Shipment and Disposal form
. U.S. Ecology, Radioactive Material Checklist
. PGE, Cask Handling Checkoff Sheet, Resin and Concentrate Liquid Waste Disposal
. PGE, Solidification and Shipping of Radioactive Waste Material Quality Control Data Sheet
. CNSI User Check-off Sheet.
No items of noncompliance were identified in this area.
5.
Lgdioactive Waste Systems With the reactor in an extended shut down condition the Liquid Waste System Vent Monitor is the only airborne effluent instrument required to be in operation. Technical Specification VII B.4. states "The liquid h
..
l
,
-
- 8-
.
.
waste system vent monitor shall nomally be in service and shall be set to alam at 10 mr/hr above background.
It may be taken out of service for maintenance purposes but shall be returned to service as soon as.
practicable..The liquid waste system vent shall be monitored routinely using portable instruments when the vent monitor is out of service.
The calibration of the vent monitor shall be checked at least once each quarter and the monitor shall be source checked at least once each week."
On June 29, 1981 while touring the Radwaste Building the inspector measured a dose rate of 0.5 mr/hr'at the liquid waste vent monitor detector. The liquid waste vent monitor was considered in service by the licensee representative. The inspector noted that the monitor was set to alarm at 100 mr/hr (full scale).
The monitor indicated less than 0.01 mr/hr (down scale).
The licensee. representative attempted to check tha monitor using the installed, source. The meter movement appeared to not respond correctly during the check.
The
. Instrument and Control Department was notified and determined the problem was due to a static charge on the monitor meter face.
Once the static charge was eliminated the instrument responded correctly to the measured dose rate.
Failure to set the liquid waste system vent monitor at 10 mr/hr above background represents noncompliance with Technical Specification VII.B.4. (50-133/81-03-01).
On July 1,1981 the inspector verified that.the liquid waste system vent monitor had been set to alam at 10 mr/hr.
During the same tour on June 29, the inspector observed inventory of scaled souces as required. by RCP-6D, " Inventory and Leak Testing of Scaled Radioactive Sources".
The five curie cobalt.60 calibration source although locked and controlled = pursuant to 10 CFR 20.203 was not labeled in a manner sufficient to infom workers of the pote'ntial dose at the well port.
The licensee representative acknowledged that the posting
.
~
and labeling of this source'should be improved.
-
~
Several other effluent monitors are maintainedfin service b' the y
licensee.
The inspector reviewed the calibration procedures < and data maintained as noted below:(',
,
Procedure
-
. Data' Reviewed OTP-11 Off-Gas and Stack Gas October 80 - June 81 Monitor Calibration and Alarm Check -and Off Gas Isolation Valve Closure Test, Revision 34
,
_,
_-
--
-
,
_
,
-
~ 9 ~,
"
,,
.c.
q
,
.
.
y i
-
,
Procedure
-
_ -Data Reviewed 0TB-13, Calibrate Area Monitors, June ~1980 - June 1981
,
Isolation Monitors, Radwaste Vent Monitors Emergency Condenser Vent Monitor, and Check Response of Continuous Air Monitors, Revision 47 OTB-13B, Source Check Emergency Londenser June 1980 - June 1981 Vent Monitor, Radwaste Vent Monitor, Area Monitor, Isolation Monitor, Process Monitor The inspector noted that the liquM radwaste discharge monitor line frequency check performed in accordance with OTB-13B has been out of specifications since March 31, 1981. A plant problem report (0P341)
was initiated to correct the observed problem. Asecondreport(0P575)
was initiated June 23, 1981 and a.esigned Priority 2 for completion.
The licensee representative stated that the frequency anomaly had little or no effect on the response of the instrument.
Equipment Description and Operating Instruction F-3, "Rao laste System",
Revision 42, and F-6, " Discharge of Laundry Batches", Revision 46 were reviewed.
F-3 states in Paragraph A.2 that:
"In order to have an accurate record of all liquid radwaste processed, l
the following records will be maintained:
1A) Waste Batch Report for laundry discharges,1B) Waste Gatch Report for waste receiver / hold Uater Inventory Report (y Discharge to Humboldt Bay Report, 3) Dailyrefer to tank discharges, 2) Dail l
'
Waste Discharge to Humboldt Bay Report.
Forms 1 ud 2 will be completed by shif t personnel at the time of treatment or discharge.
Forms 1, 2 and 3 will be reviewed by the Chemical Engineer or RPM Foreman with the required data recorded on Form 4 for the permanent record file.
Data from Form 4 will be complied in a quarterly report rad sebmitted
,
I to the NCRWQCB 'y PG&E.
Sample of each form is attached.'
o The ir,spector reviewed Form lA Nos. 81-1 thru 81-6 and Form 1B Nos. 80-1 thro 80-19 to detennine compliance with Technical Specification limits. Although the discharges were a small fraction of the allowable limits soce informality in the discharge records
were observed as noted below.
Form 18 No.
Date Comment 80-1 1-4-80 No Radwaste Monitor Reading 80-2 1-15-80 No time discharge terminated i
80-5 3 20-80 No authorization by shift foreman 80-7 3-30-80 No time discharge tenninated 80-14 11-4-80 No Radwaste monitor reading 80-16 12-4-80 No radwaste monitor reading
<
m
,
'
c
.:
-
.-
.
-10-
'
o
.
-
i
. -
-
I'
The inspector brought these omissions to the licensee's attention and l
' pointed ot.t other areas of the procedure which the inspector felt were
-
!
cumbersome and conducive to administrative error.
The Semi Annual Effluent Release Reports submitted pursuant to Technical Specification IX.I.3 were reviewed fa 1980. Verification L
of data contained in the reports against raw data maintained by the i
licensee confirmed the veracity of the-reports.
No items of noncompliance other than that indicated above (50-133/81-03-01)
were identified in this area.
6.
Exit Interview The inspector met with the licensee representative (denoted in Paragraph 1) at the conclusion of the inspection on July 2,1981.
The inspector sunenarized the scope and findings of the inspection.
In addition to the item of noncompliance discussed in Paragraph 5, the inspector brought the following points to the licensee's attention.
. The licensee's response'to IE Bulletin 80-10 is considered ine.omplete.
. The manner in which the nominal 5 Ci cobalt calibration source is posted should be improved.
l
. The liquid radwaste procedures need revision to be more consistant l
with Technical Specification requirements.
,
. Site procedures need to be reviewed gnd revised in accordance with NPAP E-4. -
. The solidification and disposal of waste concentrates during 1980 appears to have been handled in a professional manner consistant with regulatory requirements.
~
,
-
l l
,
~
l
'
,
,
,.
'
.
!
'
O.
~1
,
,
,
I
'
l
+
>
i
.
-
.
!
I
.
e d
u---
-
a,
._