IR 05000213/1987014

Insp Rept 50-213/87-14 on 870504-08.No Violations or Deviations Noted.Major Areas Inspected:Solid Radwaste Processing & Preparation,Packaging & Shipping Program, Including Previously Identified Items & Qa/Qc

ML20215L444
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/08/1987
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215L420	List: IR 05000213/1987014 ML20215L418
References
50-213-87-14, GL-81-38, IEB-79-19, IEIN-84-50, IEIN-86-020, IEIN-86-20, IEIN-87-003, IEIN-87-007, IEIN-87-3, IEIN-87-7, NUDOCS 8706260053
Download: ML20215L444 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

LReport N /87-14 Dock'te N License N OPR-61 Category. C

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Licensee: ' Connecticut Yankee Atomic Power Company Facility Name: Haddam Neck Power Station Inspection At: Haddam Neck, Connecticut Inspection. Conducted: May 4-8, 1987 Inspectors: .(. b lo!8f@ 7 H.J. Efice e Radiation Specialist date

\ / ) l Approved by _ .~- 4-O G c- \)

'W. Pasciak, Chief, Effluents Radiation d / Y [('l-Protection Section, DRSS

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Inspection Summary: Inspection May 4-8,1987, (Report No. 50-213/87-14)

l Areas Inspected: Routine unannounced safety inspection by a regionally-based I inspector of the licensee's solid radioactive waste processing, preparation, j packaging and shipping program including: previously identified items, organ-ization, procedures,. indoctrination / training, quality assurance / quality i control,. radiochemistry, low-level radioactive waste facility, processing / storage, radioactive waste generator and radioactive shipper

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Re;ults: No violations or deviations were identified. The licensee appeared to be systematically improving performance in the solid radioactive waste pr'. gra '

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8706260053 070604 PDR G ADOCK 05000213 PDR  !

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DETAILS Personnel Contacted 1.1 Licensee Personnel

• Miller, Jr. , Station Superintendent

• J. Beauchamp, Quality Assurance (QA)/ Quality Control (QC) Supervisor

• G. Bouchard, Unit Superintendent ,

• H. Clow, Health Physics Supervisor

• E. DeBarba, Station Services Superintendent G. Goncarovs, Radiochemist

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Haight, Radioactive Material Handling Supervisor

• J. LaPlatney, Station Services Superintendent Staff Assistant P. L'Heureux, Engineering Supervisor, Mechanical Engineering

, F. Libby, Supervisor, Operations QA C. Martin, Engineer, Mechanical Engineering W. Nevelos, Radiation Protection Supervisor

• M.~ Sforza, Senior Engineer, QA Other licensee personnel were also contacted or interviewed during the inspectio .2 NRC Personnel

• A. Asars, Resident Inspector P. Swetland, Senior Resident Inspector

• Attended the exit interview on May 8, 198 . Scope of the Inspection i

This routine inspection reviewed the licensee's solid radioactive waste (radwaste) processing, preparation, packaging and shipping program as implemented by the licensee from March 15, 1986 through May 8, 198 During the period the licensee made approximately 29 shipments. A sample of 9 shipments providing examples of shipments of dry active waste (DAW),

dewatered resins, filters, solidified radwaste materials and special decontamination resins was selected and reviewed relative to the licen-see's Technical Specifications, radwaste generator requirements in 10 CFR 20.311 and 10 CFR 61.55-56 and radioactive materials shipper requirements in 10 CFR 71 and 49 CFR 170-189. In addition, the licensee's new Radwaste Reduction Facility was reviewed relative to regulatory requirements and guidance provided in NRC-NRR Generic Letter 81-38, " Storage of Low-Level Radioactive Wastes At Power Reactor Sites," dated November 10, 1981 and its enclosure concerning radiological safety. The licensee's actions regarding previously identified items were also reviewe .

. 3 Previously Identified Items On June 18, 1986, an Enforcement Conference was held with the licensee at the NRC Region I office to discuss violations and programmatic weaknesses noted during Inspection No. 50-2.?3/86-0 .1 (closed) Violation (50-213/86-04-01) Radwaste procedures did not ;

provide for verification of radionuclides in radwaste shipment Licensee corrective actions (including training, changes to radwaste handling procedures and independent review of radionuclide identifi-cation and activity) as described in the licensee's letter (dated i

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August 21,1986) were reviewe Corrective actions as described had been completed. This item is closed, l j

3.2 (closed) Violations (50-213/86-04-02; 86-04-03; and 86-04-04). Fail-ure to indicate the radionuclide identify, quantity and total radio-activity for Iron-55 on radwaste manifests and radioactive shipping

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records and certification that the radwaste was properly described when Iron-55 had been omitted. Licensee corrective actions (includ-ing updates to shipment records, improvements to procedures and independent verification of radionuclide identities and activities)

as described in the licensee's letter (dated August 21, 1986) were reviewed. The licensee had completed the corrective actions as described. These items are close l 3.3 (closed) Followup Item (50-213/86-04-05). Review details and correc-tive actions regarding a radwaste technician receiving higher than expected exposure connecting a high integrity container (HIC).

The licensee made changes to HIC receipt inspection procedures to ensure that HI-C fittings and dewatering fittings were compaticle. In addition, " continuous" health physics technician job coverage was redefined to mean the technician remained at the jobsite in cotmuni-cation with the radwaste technician. The licensee is also consider-ing improvements to the " Spent Resin Pit" area to improve radiation exposure contro This item is close . Organization The organizational structure of the license's Psadioactive Materials Hand- '

ling (RMH) group was reviewed. The RMH group (in the Radiation Protection Department) is comprised of 9 RMH Technicians supervised by the RMH Super-visor. The RMH Supervisor reports to the Radiation Protection Supervisor who in turn reports to the Health Physics Supervisor. The licensee is considering the appointment of an Assistant RMH Supervisor to assist the RMH Supervisor. The responsibilities of the RMH Group appeared to be clearly defined in the licensee's procedures and no concerns were note . Procedures The licensee's procedures for processing, preparation, packaging and shipping solid radwaste materials were reviewed relative to criteria provided in 10 CFR 20.311, 71.5, 71.12 and Technical Specification 6.8, '

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. 4 Procedures," and commitments provided during the 1986 Enforcement Con-ference. The following procedures were reviewed, discussed with the licensee and checked for implementation: l l

Licensee Procedures Nuclear Engineering and Operations Procedure (NED) 6.07, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification, Packaging and Transportation," Revision 0, March 25, 1986; 2 Administrative Control Procedure (ACP) 1.2-2.9, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification, Packaging and Transportation," Revision 1, July 23, 1986; ACP 1.2-13.5,'" Entry and Exit From Station'of Transporter.for Nuclear i By-Products Material (Radwaste), Revision 12, February 25, 1987;

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Radiation Protection Procedure (RAP) 6.3-5, " Radioactive Material Management," Revision 33, April 28, 1987;

Radiation. Protection Procedure (RAP) 6.3-5, " Radioactive Material Management, Revision 33, April 28, 1987-

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RAP 6.3-9, "Use of USNRC Certified Radioactive Material Packages,"

Revision 4, April 6, 1987; RAP 6.3-10, "Radwaste Package Curie Calculations and 10 CFR Part 61 Calculations," Revision 3, April 6, 1987; RAP 6.3-11, "Quali_ty Assurance Program for Radwaste Package Calculations," Revision 2, April 6, 1987; and

' RAP 6.3-12, " Sampling Guidelines for 10 CFR Part 61 Compliance,"

Revision 2, April 1, 198 Vendor Procedures NUS Process Services SS-001, " Process Control Program for Radwaste Solidification Service," Revision J, adopted by the licensee on j October 6, 1986; and l NUS Process Services, SS-013, " Operating Procedure for NUSPSC Radwaste Solidification System No. 8901, " Revision B, adopted by the ,

licensee on May 22, 198 J

In view of concerns raised during Inspections Nos. 50-213/85-09 and {

50-213/86-04 for the licensee's QA/QC program application to solid rad- l waste, the licensee developed NE0 6.07 detailing corporate instructions for implementing QA/QC requirements. ACP 1.2-2.9 was developed to provide j

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4 instructions for implementing those requirements.at the station. Review of the procedures and'ACP 1,2-13.7 indicated that a clear delineation of responsibilities had been provided and.each aspect of the quality control of dewatering, solidification, packaging and shipping activities had ,been

, addressed. Review of, station QA/QC records. indicated that the procedures were being' implemente RAP.Nos. 6. 3-10,~6.3-11, and 6.3-12 were developed by the licensee to provide detailed. instructions -and-uniform methods for assuring that cal . 1

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culations of.radwaste package activities and classifications were properl completed.' independently reviewed and changes .to the database were made as-

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needed. Those.' procedures incorporated changes and upgrades discussed-at the Enforcement; Conference,-Review of selected shipping records showed'

that the' procedures were being implemente Review of'the remaining licensee and vendor procedures showed those pro-cedures to be in conformanc'e with the criteria above and being' implement-

'ed. The. licensee appeared.to have' strengthened existing procedures, developed and. implemented new procedures and, generally upgraded QA/QC procedures i'n response to findings in Inspection Report No. 50-213/86-0 No violations or additional concerns were noted in this revie ' Indoctrination and Training

.The licensee's' indoctrination and training program (as it related to solid radwaste processing, preparation, packaging and shipping activities) was-reviewed relative-to commitments in the licensee's responses to NRC-IF,.

Bullet.i.n No. 79-19_and. findings in Inspection Report No. 50-213/86-04, Training provided for the RMH Supervisor, RMH technicians, site-QA/QC personnel.and. corporate QA auditors during 1986-87 was reviewed and discussed with the licensee, The licensee provided. training inhouse and at'the~ChemNuclear Services, Inc. facility in Barnwell, South Carolin No deviations.from commitments were note . . Quality Assurance / Quality Control Under Technical Specification 6.18, the licensee is required to operate l the solid radwaste treatment system in accordance with a Process Control Program (PCP) to process wet radwaste materials to meet shipping and disposal requirements. Specific quality' control requirements are also (

mandated by 10 CFR 20'.311 to assure compliance with 10 CFR 61.55-56. The i

. establishment of a quality assurance program for the packaging and trans- )

portation of radioactive materials is required by 10 CFR 71, Subpart H. A ;

Commission-approved quality assurance program which satisfies the applic- !

able criteria of 10 CFR 50, Appendix B and which is established, t maintained ~and executed for transport packages is acceptable to meet the i requirements.of 10 CFR 71, Subpart Guidance regarding applicable-criteria for a quality assurance program for transport packages was provided in NBC-IE_Information. Notice No. 84-50. The licensee elected to apply-the currently established 10 CFR 50, Appendix B, quality assurance

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program to packaging and shipping activities. In addition, NRC-IE~~

Information. Notice No. 86-20 provided guidance on classification requirements under 10 CFR 61.55. NRC-IL Informat. ion Notice No. 87-07 reminded licensees of their responsibility to ensure process control of vendor-supplied service j l

7.1 Waste Generator Quality Control / Process Control Program l The licensee's quality control program to ensure proper classification under 10 CFR 61.55 and proper waste form under 10 CFR 61.56 was reviewed. The inspector noted that:

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Samples .from the licensee's dry active waste, routine ion-exchange resins, decontamination ion-exchange resins, reactor coolant, reactor coolant pump oil, evaporator residues j and filters were taken and sent to a contractor for analysis l

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Scaling factors (under 10 CFR 61.56(a)(8)) for determining the activities of difficult-to-measure radionclides were determined by the contractor, incorporated into procedures and ,

computer-based classification databases by the licensee and used !

to determine those radionuclides; I

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Independent verifications of calculations of radionuclide activities were made and recorded; j l

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Verification of dewatering for ion-exchange resins in HICs and l filters in liners were required at appropriate steps in i procecures, independently inspected by quality control-personnel and recorded in radioactive material shipping records; and

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Test solidification of samples, control of key process parameters (e.g. pH and mixing speed for cement addition),

verification of final solidified waste form and independent inspection of designated hold points by quality control personnel were also completed. The licensee appeared to have implemented a generally adequate process control program for waste classification and waste from quality contro .2 Waste Shipcer Quality Control / Quality Assurance

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The site.QA Organization was responsible for implementing all j applicable QA criteria to packaging and transportation of solid I'

radwaste, The Corporate QA organization was responsible for performing QA audits, j

The quality control organization provided verification of packaging !

compliance, (i.e. " receipt inspections"), upon arrival at the sit A checklist to verify compliance with applicable items of the j

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. pack' aging Certificate of Compliance (C0C) was used prior to shipment departure. Implementation'of the NE0 6.07 requirements (established for the site in ACP 1.2 - 2.9) was evidentLin.the shipments reviewed for the following: .

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activity.surveillances of procedures for sorting, compacting and surveyi.ng dry. active wastes;

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-designated hold' points in. process procedures for the solidification of'the decontamination ion-exchange resins; and

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inspections of packaging, labeling and shipping requirements a .

' appropriate to the type shipment of 10 CFR 71 and 49 CFR 1170-18 Site QA: organization involvement in the operation of- a vendor radwaste mobile solidification system was'. reviewed. As noted in-Detail 7l.1, the licensee had increa' sed QA involvement in the process-of preparing a liner for cask shipment. . In the shipments.o solidified evaporator' residues and decontamination ion-exchange resins examined,.the site QA/QC organization performed inspections of-designated.halfpoints, monitoredcprocedural adherence'and tracked.the individualLshipping containers from, receipt to release from the sit The inspector noted that these activities had 'significantly increased site-QA Involvement i.n the preparation,. packaging and shipping- !

activities over that noted in Inspections Nos. 50-213/85-09 and

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50-213/86-0 The inspector _ reviewed corporate QA Audit.A60260 conducted August 6 -

September 12, 1986 of Radwaste Packaging and Transportation activitie The audit was conducted by two trained auditors with assistance from the licensee's-Radiological Assessment Branch fo verification of waste classification. The audit-appeared to

. programmatically review applicable criteria from 10 CFR 50, Appendix 8 (in general. agreement with guidanca in NRC-IE..Information . Notice

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1. N ).. However, the audit failed to review ve6 dor 'solidifica-tion activities. A subsequent monthly health physics audit (NE-86-RA-911) by representatives of the licensee?s Radiological Assessment Branch reviewed that aspect of the licensee's program and was referenced in QA Audit A60260. Together the audits covered all aspects of the licensee's sclid radwaste program and represented an improvement in audit practices .'oted in earlier reviews, The

' , , licensee's audit of vendor solidification activities was responsive

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to concerns.in NRC-IE In. formation Notice No. 87-0 . Radiochemistry The inspector briefly reviewed licensee fuel performance data, ion-exchange resin characteristics and " CRUD" behavior with the licensee's radiochemist to determine the general adequacy of the licensee's sampling and vendor analysis program for difficult-to-identify radionuclide ..

. 8 Calculated fuel failure rates for 1985 and 1986 were 4.73E-3% and Sg7E-3%

respectivel Neptunium-239 was found in the reactor coolant water in 1985 and 1986. High colloidal removal ion-exchange resins were not used in'the primary coolant system but were used in radwaste processing ion-exchange resins. No " CRUD" bursts exceeding 7 days duration were noted during the period reviewed. Cesium and iodine ratios in the primary coolant did not indicate significant fresh fission product activity indicative of significant fuel failur Within the area of this brief review, the licensee's annual sampling and analysis program ~ appeared adequate to characterize the various waste 1 streams processed for disposa l

. Low-Level Radwaste Facility The licensee designed and was completing an approximately 5,000 square feet low-level radwaste processing and storage facility for dry active wast Two Plant Design Change Requests (PDCR) were used for the construction, i.e. PDCR 85-733, " Civil-Structural," and PDCR 85-793,

" Building Services." The facility was nearly complete, lacking installa-tion of the shredder and compactor processing units and area radiation and airborne radioactivity monitor The structure was originally scheduled for operation by January 1986, but construction was delayed. Floor space

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within-the facility was divided by 12-inch thick solid concrete black walls of varying heights into sorting, shredding-compacting, storage and shipping area The design, construction and planned operation of the facility were reviewed against criteria and guidance provided in: '

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10 CFR 20.106, " Radioactivity in Effluents to Unrestricted Areas,"

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10 CFR 50.59, " Changes, Tests and Experiments,"

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10 CFR 100, " Reactor Site Criteria," (as modified in NRC-NRR Generic Letter 81-38); and

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NRC-NRR Generic Letter 81-38 and its enclosure entitled " Radiological Safety Guidance For Onsite Contingency Storage Capacity."

Selected documents related to design of the facility were reviewed and i discussed with the licensee and tha facility was toured to determine the j licensee's compliance with the criteria and guidance above. The following '

aspects of the design and projected operation of the facility were reviewed:

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projected off-site doses from normal operations and postulated !

accidents;

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radiological monitoring of potential release pathways; l - - _ _ _ _ _ i

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personnel radiation protection within the facility;

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limitations on stored waste forms, containers and total stored j radioactivity;

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flow patterns for waste processing including projected equipment ;

operation, storage and shipping activities; and

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planned development of operating and administrative control procedure The inspector noted that the PDCRs had been reviewed and approved and the modification was being completed under 10 CFR 50.59. The licensee had concluded.that the facility did not create an unreviewed safety question i as defined in 10 CFR 50.59 and did not involve a change to the licensee's . .j Technical Specification ;

Within the scope.of this review, no violations were note The licensee appeared to be developing an adequate low-level radwaste processing and storage facility for dry active wast ]

1 Solid Radwaste Processing / Storage The inspector reviewed the licensee's. solid radwaste processing activities including operation of the evaporator, resin dewatering in the Spent Resin -

Pit, vendor-supplied solidification of evaporator residues and decontamination resins and segregation of hazardous and low-level radwastes (i.e. NRC-IE Information Notice No. 87-03). Licensee reports ;

summarizing solid radwaste~ operations ~were reviewed for obvious mistakes, anomalous measurements of radioactivity and omissions. The licensee's sampling and analysis of the following radwaste streams was also reviewed:

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Reactor-Coolant System;

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Aerated drain demineralizer resins; i

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Aerated drain filters;

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Radwaste evaporator feed;

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Dry active waste; i

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Reactor Coolant Pump-011;

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Steam Generator Decontamination Resins and Chelating Agents; and !

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Chemical and Volume Control System demineralizer resin Temporary onsite storage of solid radwaste was also briefly reviewe Within the scope of this review, no violations were identifie i l

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, 10 1 Radwaste Generator Requirements From March' 15, 1986 through May 8,1987, the licensee made 29 solid

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'radwaste' shipments as summarized below:

Type Number 1986 1987 (through May 8, 1987)

Dewatered Resins 0 2 Filters 2 0 Dry Active Waste 6 3 Solidified Evaporator Residues 14 0

• "Special" 0 2 Totals 22 7

• Solidified decontamination resins resulting from the decontamination of two steam generators and containing chelating agent The inspector selected a sample of a shipment representing each radwaste type and reviewed each against the following radwaste generator requirements:

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Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);

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Waste Classification under 10 CFR 20.311(d)(1) and 10 CFR 61.55;

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Waste Form and Characterization under 10 CFR 20.311(d)(1) and 10 CFR 61.56;

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Waste shipment labeling under 10 CFR 20.311 (d)(2) and 10 CFR 61.55;

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Tracking of waste shipments under 10 CFR 20.311(d), (e), (f) and (h);

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Disposal site license conditions under Technical Specification 6.18 for South Carolina Radioactive Material License No. 97 for the !

Barnwell sit Within the scope of this review, no violation were note . Radwaste Shioping Requirements The 9 shipments described in Detail 2 were reviewed against criteria provided in 10 CFR 71 and 49 CFR 170-189 to determine if transportation requirements had been me .1 Procurement and Selection of Package The licensee's selection of packages for the 9 shipments was reviewed relative to requirements in 49 CFR 173, " Shippers-General Requirements for Shipments and Packaging," and 10 CFR 71.12, " General

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, 11 License: NRC Approved Package." The licensee's performance relative to the criteria was determined by interviews with Radioactive

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Material Handling Group personnel, discussions with Quality Control '

personnel and review of documents and shipping record l Within the scope of this review, no violations were identifie .2 Preparation of Packages for SFipment The licensee's preparation of the packages for shipment was reviewed relative to the requiremeits of 49 CFR Parts 172 and 173, 10 CFR 71.87 and Technical Sr;cifications. The licensee's performance !

relative to the m iteria was determined by interviews of. licensee !

personnel and examination of procedures, shipping records and other-document .Within the scope of this review, no violations were note ,

12.3 Delivery of Packages to Carriers l The licensee's delivery of packages to carriers was reviewed relative !

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10 CFR 71.5(a)(1)(iii), " Placarding;"- l

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10 CFR 71.5(a)(1)(vi), " Shipping Manifests;" .

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applicable Technical Specifications and procedure The licensee's performance relative to the criteria was determined by review of shipping records and discussion with cognizant licensee personne Within the scope of this review, no violations were identifie .4 Transportation Incidents The licensee stated that no transportation problems had been noted and no violations or warnings had been received from the State Regulatory agancies regarding their shipments during the period reviewe . Exit Interview The inspector met with the licensee's representative (denoted in Detail 1)- '

at the conclusion of the inspection on May 8, 1987. The inspector summarized the scope of the inspection and findings as described in this repor .

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~, * 12 The inspector discussed the improvements in QA/AC noted and positivoL overall trend noted in the solid radwaste progra At not time during this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure'under 10 CFR 2.790 is discussed in this report.

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