IR 05000219/1979023
| ML19305C476 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/31/1980 |
| From: | Crocker H, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19305C453 | List: |
| References | |
| 50-219-79-23, NUDOCS 8003280643 | |
| Download: ML19305C476 (21) | |
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G U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-219/79-23 Docket No.
50-219 License No.
OPR-16 Priority Category C
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Licensee:
Jersey Central Power and Light Company Madison Avenue at Punch Bow! Road Morristown, New Jersey 07960 Facility Name:
Oyster Creek Nuclear Generating Station Inspection At:
Forked River, New Jersey Inspection Conducted: December 9-14, 18-19, 1979 and January 4,1980 Inspectors:
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R. L. Nimitz, Radiation Specialyt ~
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r date date Approved b
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H. W. Crocker, Acting Chief, Radiation Support Section
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Inspection Sumr,1ary:
Inspection on December 9-14, 18-19, 1979 and January 4, 1980 (Report No. 50-219/79-23)
Areas Inspected:
Routine, unannounced inspection by one regional based inspector of the Radioactive Waste Managem2nt System during operation including:
liquid and gaseous radioactive effluent releases; reactor coolant water quality; calibration and functional tests; standby gas treatment system; planning and preparation; solid radioactive waste and training.
Also licensee action on IE Bulletin 79-19, and Licensee Event Report 50-219/79-41/3L-0.
Upon arrival at the site on December 9,1979 at 9:00 p.m., areas where work was being conducted were examined to review radiation safety control proce-dure adherence and practices.
The inspection involved 63 inspector-hours on site by one regional based inspector.
Results: Of the nine areas inspected, no items of noncompliance were identified in 7 areas, four items of noncompliance were identified in two areas (infraction -
failure.to survey to meet 10 CFR 20.201, paragraph 8; infraction - failure to i
meet 10 CFR 71.3, paragraph 8; deficiency - failure to maintain records pursuant
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to 10 CFR 71.62, paragraph 8; infraction - failure to file request for change in l
Technical Specifications as required by 10 CFR 50.59(c), paragraph 2).
Region I Form 12
l (Rev. April 1977)
S0032806
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DETAILS 1.
Persons Contacted S. Fuller, Assistant QA Supervisor T. Johnson, Instrument and Electrical Maintenance Supervisor J. Maloney, Station Operations Supervisor R. Pelrine, Chemical Supervisor J. Riggar, Security Supervisor The following individuals attended the preliminary exit interview held on December 14, 1979:
- W. Garvey, Director Station Administration C. Lefler, Radioactive Waste Supervisor
- J. Sullivan, Unit Superintendent D. Turner, Supervisor Health Physics Including those individuals denoted above by *, the following individuals attended the final exit interview held December 19, 1979 J. Carroll, Jr., Station Manager K. Fickeissen, Plant Support Superintendent The inspector also met with licensee representatives on January 4,1980.
The meeting addressed licensee action taken with respect to Immediate Action Letter (IAL) No. 79-21 dated December 26, 1979.
The following licensee representatives were present:
J. Carroll, Jr., Station Manager K. Fickeissen, Plant Support Superintendent J. Sullivan, Unit Superintendent The inspector also talked with and interviewed several other licensee employees, including members of the Health Physics (H.P.) staff (station and contractor) chemistry stiff 2nd reactor operations and maintenance personnel.
2.
Licensee Event Report (LER)
The inspector reviewed licensee follow-up action with respect to LER No.
50-219/79-41/3L-0 dated December 3, 1979.
The LER detailed operation of the New Radwaste Exhaust Ventilation Monitoring System in a manner which could not yield accurate radioactive effluent data for gaseous releases from the New Radwaste Building.
The system had been operated in this manner since initial introduction of radioactive material into the building in October 1978.
The inspector noted this item to have been identified during an NRC inspection conducted in October and November 1979 (Inspection 50-219/79-18).
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i The inspector review of licensee IAL actions regarding the above ar.d subse-quent discussions with licensee representatives indicated the following licensee actions have been taken.
The licensee has performed a preliminary evaluation of the current
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effluent releases from the New Radwaste Building Exhaust.
The evalua-tion, performed December 21, 1979, indicated current releases are within regulatory limits.
The licensee plans to evaluate gaseous, particulate and iodine releases that have been released from the facility with respect to allowable release rates and total radio-activity relecsed. These releases will be reported by the licensee on or before March 30, 1980.
The licensee's corporate office has been tasked the evaluation of
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automatic ventilation isolation upon high alarm.
The licensee has performed a calibration of the gaseous effluent moni-
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toring channel. The calibration completed December 27, 1979, using gross gaseous activity obtained from the air-ejection offgas system, resulted in the completion of a calibration curve ranging to 10,000 cpm.
The licensee is evaluating particulate and iodine releases via analysis
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of sampler cartridges.
The analysis comenced once per week beginning November 21, 1979. The licensee has subsequently begun analyses twice per week as of December 10, 1979.
The licensee has evaluated current alarm set points for the gaseous
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channel. The licensee's preliminary evaluation indicated Xe-135 as the limiting isotope. The preliminary licensee evaluation resulted in ventilation isolation alarm setpoints lowered from 80,000 cpm to 4,000 cpm.
The licensee representatives indicated further review of alarm setpoints will be completed to allow for instantaneous releases.
The inspector noted the above actions met adequate IAL licensee action requirements.
The inspector indicated the following will be reviewed during a sub-sequent inspection (50-219/79-23-16)
Licensee final evaluation of alarm setpoints.
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Licensee evaluation of ventilation isolation requirements.
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Previous New Radwaste Building effluent releases.
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10 CFR 50, Domestic Licensing of Production and Utilization Facilities, Section 50.59, Changes, Tests and Experiments, specifies in paragraph (a)
that the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety analysis report, l
without prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question. Additionally,10 CFR 50.59(c) specifies that the holder of a license authorizing operation of a utilization facility who desires to make a change in technical specification or a change in the facility as described in the safety analysis report shall submit an appli-cation for amendment of his license.
During review of the New Radwaste Building and associated operations the inspector noted that the construction of and operation of this building constituted a change in the facility as described in the safety analysis report in that the New Radwaste Building and its associated operations were not described in the safety analysis report. Additionally, the operation of this facility introduced a new radioactive effluent release point to the atmosphere and as e result required a change to the technical specifi-cations to incorporate this new release point into limiting conditions for operation.
The inspector review of the above indicated the licensee had submitted a Final Description and Analysis of the Liquid / Solid Radioactive Waste Treat-ment System to the Commission in April of 1977, however, the submittal indicated proposed Technical Specifcations were to be submitted by October of 1977, approximately four months prior to the inservice date of the Liquid / Solid Radwaste Building.
Inspector review of licensee submittals and discussions with licensee representatives indicated that as of December 10, 1979, approximately one year after operation of the New Radwaste Facility, no application for amendment of the reactor license addressing proposed technical specifications for radioactive effluents released from the New Radwaste Building had been
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made. The inspector noted that the proposed technical specifications that have been submitted addressed Radwaste Building settlement in soil.
The inspector indicated to licensee representatives, that failure to submit an application for amendment of the facility license addressing radioactive effluent release from the New Radwaste Facility constitutes noncompliance with 10 CFR 50.59(c) (50-219/79-23-01).
Licensee representatives indicated submittal of Technical Specifications addressing this area will be made by March 1,1980.
3.
Liquid and Gaseous Radioactive Effluent Releases The inspector examined the licensees radioactive liquid and gaseous effluent releases against the requirements of Appendix A to License No. DPR-16,
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Section 3.6, Radioactive Effluents.,(Surveillance Requirements)(Limiting Con Section 4.6, Radioactive Effluents
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Gaseous Effluent Releases
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The inspector reviewed the following procedures and data generated to meet Technical Specification surveillance requirements for gaseous and particulate effluent releases.
The data reviewed covered surveillance tests performed for the periods January 1978 thru November 1979.
Procedure No.
Title Rev. No.
Dated 804.2 Air Ejector Off-Gas Gross
9/7/77 Gamma 24 hr/2 hr Ratio 804.3 An Ejector Off-Gas Gamma
9/7/77 Spectrum 804.15 Tritium in Off-Gas and
9/7/77 Gland Seal Exhaust 1207.6 Stack Gas Releases, Parti-
12/8/78 culate Filter Activities 1207.10 Stack Gas Releases of Iodines
4/3/78 and Particulates Using the TN-11 MCA System 804.27 Stack and Off-Gas Monitor
9/12/77 Calibration The inspector noted that for the period reviewed, plant stack effluent release rates of iodines and particulates with half lives longer than eight days appeared to average less than 10% of the allowable limit delineated in Technical Specification (T.S.) Section 3.6 A. (2) (i.e. <4 pCi/sec).
Additionally, the inspector noted the release rate of gross activity from the plant stack, excluding iodines and particulates with half lives longer than eight days appeared to average less than 20% of the T.S. limit delineated in Section 3.6 A. (1).
The inspector discussed the above finding with licensee representatives who indicated that the Augmented Off-Gas Treatment System was not in operation due to mechanical problems, which resulted in above average gross activity release from the plant.
The inspector noted nonoperation of the Off-Gas system to be in review by NRC Licensing personnel.
No items of noncompliance were observed in this area.
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b.
Liquid Effluent Releases The inspector reviewed the following procedures and associated data generated to meet Technical Specification surveillance requirements for liquid effluent releases for the period sJanuar,1978 thru November 1979.
Procedure No.
Title Rev. No.
Dated 803.3 Radioactive Liquid Waste
7/26/77 Composite Sample 804.6 Liquid Radwaste Composite
9/7/77 804.32 Liquid Radwaste Isotopic
9/13/77 Discharge to Environment 812.10 Liquid Radioactive Waste
6/21/77 Control Limits and Correc-tive Action 812.11 Radwaste Equipment Opera-
6/23/77 bility Control Limits and Corrective Actions The inspector also reviewed completed Form 818.16, " Radioactive Liquid Waste Analysis and Release Permit" and associated documentation.
The inspector noted procedure 804.32 to require in step 5.10 and 5.11 that group shift supervision must sign form 818.16 prior to and after termina-tion of releases and transfers.
No items of noncompliance were observed.
c.
Outside Tank Activity The inspector reviewed documentation of surveillance activities gene-rated to meet Technical Specification 3.6.c., Radioactive Liquid Storage, requirements.
The inspector review encompassed surveillance requirements performed in accord with licensee procedure 806.14, Rev. 1, " Estimation of Rad Waste Outside Tank Activity" dated August 11, 1977.
The inspec-tor reviewed selected original Form 818.36, "Radwaste Total Outside Storage Tank Activity," generated during the period sJanuary 1977
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l thru June 1979. The inspector'noted sample frequencies and tank analysis results appeared to meet the abcve requirements.
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No items of noncompliance were observed in this area.
4.
Reactor Coolant Water Quality z'
The inspector reviewed records of reactor coolant system chemistry and total iodine concentration for compliance with the requirements of Tech-nical Specification 3.3.E, Reactor Coolant Quality (Limiting Conditions for Operation) Technical Specification 3.6,0., Reactor Coolant Radioactivity (Limiting Conditions for Operation) and associated surveillance requirements as delineated in Technical Specification Section 4.3 and 4.6.
The inspector reviewed the following surveillance test procedures and test data for the period sJanuary 1978 through November 1979:
Procedure No.
Title Rev. No.
Dated 802.2 Instructions for Use of
8/19/77 Chemical Sampling Schedules 804.1 Reactor Water Analysis
2/3/78 805.2 Conductivity
6/4/76 805.3 Chloride Ion
12/26/75 I
805.38 Chloride Ion Using Perkin-
9/12/77 Elmer Model 200 Spectrophotometer 812.1 Reactor Primary System Control
12/2/77 Limits and Corrective Action The inspector noted that, for the period reviewed, reactor coolant total iodine averaged $1.0 uCi/cc, iodine 131 averaged s6.4 E-3 uCi/cc, conduc-tivity ranged from 0.1 to.5 umhos/cm and chloride ion was nominally less than 50 ppb.
The data reviewed by the inspector indicated surveillance test frequency and results of coolant analysis was within technical specification limitations.
During inspector review of the above procedures, it was noted that several
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l chemistry procedures appeared to have been generated in 1977 and earlier.
The procedures noted included, procedure 805.2, dated 6/4/76; procedure 805.3,' dated 12/26/75; procedure 805.4, dated 12/26/75 and procedure 805.38, dated 9/12/77.
l The-inspector noted licensee administrative procedure 107, Rev.1 "Proce-dure Control" dated September 27, 1979 specifies in Section 3.0, Respon-
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sibilities that the chemical supervisor is responsible for periodic review
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of 800 series procedures.
Further, section 3.0 requires review of the above procedures every two years.
The inspector discussed the status of 800 series procedure review with the chemical supervisor and noted September 1979 to be the end of the latest two year period.
The chemical supervisor indicated that as a result of chemical staff terminations, and subsequent rehiring and familiarization, the procedure review was only recently (sNovember 1979) initiated.
The inspector indicated that 800 series procedures review would be examined during a subsequent inspection (50-219/79-23-02).
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No items of noncompliance were observed in this area.
5.
Calibration and Functional Tests Die inspector reviewed calibration and functional test data for main steam line, air ejector off-gas, stack gas and radwaste liquid effluent radiation monitoring channels against the surveillance requirements of Technical Specification Table 4.1.1, Minimum Check, Calibration and Test Frequency for Protective Instrumentation and Technical Specification Section 4.6
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Radioactive Effluents.
The review encompassed data generated for the period sJanuary 1978 through sNovember 1979.
The inspector review also encompassed licensee procedural requirements as contained in the following licensee procedures:
Procedure No.
Title Rev. No.
Dated
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116 Surveillance Test Program
9/27/79 Schedule and Review of
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Test Results 621.3.002 AEOG Radiation Monitor
6/8/79 Test and Calibration 621.3.003 Main Steam Line Radiation
9/30/77 Monitor Test and Calibration i
621.3.004 Process Radiation Monitor
11/21/79 Calibration i
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621.3.009 Main Steam Line Radiation
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Monitor Front Panel Calibration 621.4.006 Stack Gas and Radwaste Liquid
4/3/78 Effluent Monitor Front Panel Test
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Procedure No.
Title Rev. No.
Dated 621 4;006 Stack Gas and Radwaste
4/3/78 Liquid Effluent Monitor
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Front Panel Test i
i 621.4.007 AEOG Radiation Monitor
3/7/79 Front Panel Test 621.4.008 Main Steam Line Radiation
8/1/79 Monitor Front Panel Test No items of noncompliance were observed in this area.
6.
Stan "3y Gas Treatment System The inspector reviewed tests of the Standby Gas Treatment System (SGTS)
for compliance with the requirements of Technical Specification 4.5.K, Standby Gas Treatment System (SGTS).
a.
Procedure Review The following surveillance test procedures, generated to meet Techni-cal Specification 4.5.K surveillance requirements, were reviewed by the inspector. The review encompassed performance of the procedure and the requirements of Technical Specification 6.8, Procedures. The results reviewed were the period Wanuary 1978 through November 1979.
Procedure No.
Title Rev. No.
Dated 651.2.004 Standby Gas Treatment System
5/5/78 Electric Heating Coil Test 651.3.002 Particulate Filter Efficiency
5/31/79 Test 651.3.003 Charcoal Filter Efficiency
5/31/79 Test 651.4.001 Standby Gas Treatment System
8/11/78 I
Test l
651.4.005 Standby Gas Treatment System
4/6/78 Hepa Filter AP Test During review of data sheets associated with procedure 651.4.001 the
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following test data was noted for SGTS No. 2.
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In-Line Pitot Filter AP (in. H20)
Test Date Flow (CFM)
AP (in)
Upstream Downstream 2/27/79 2500 1.8 1.8
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3/28/79 3300
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4/24/79 2350
.30 1.8 1.9 The inspector discussed the above test data with licensee representatives, particularly with respect to the data of 3/28/79.
The inspector noted that no basis could be given for the anomolous data.
The inspector expressed concern with the above particularly since the data for the 3/28/79 test indicated that HEPA filters were apparently not in place during the test.
Discussions with cognizant licensee representatives and review of Surveillance Test Backsheet did not indicate lack of filters.
The inspector noted the surveillance test to have been reviewed as required by licensee administrative procedure 116, Rev. 4, " Surveillance Test Program Schedule and Review of Test Results" dated August 8, 1979.
The inspector noted the test to have been reviewed and approved by four individuals.
The inspector indicated that licensee action taken to ensure anomolous surveillance test data has received a thorough examination prior to being indicated as satisfactory, will be reviewed during a subsequent inspection (50-219/79-23-03)..
The inspector noted during review of procedure 651.4.001, that Step 6.5.4 requires the tested standby gas treatment system to be returned to standby readiness in accordance with operating procedure No. 330 " Standby Gas Treatment System" after performance of the 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> test.
The inspector also noted step 6.3.7 of this procedure to require verification of SGTS initiation and proper valve alignment.
In reviewing the data sheet for this test, the inspector noted check-offs for " Valve Alignment Correct (Operations Procedure 330)". The inspector questioned licensee representa-tives as to whether this was valve alignment prior to test or after test.
The inspector discussed the above with licensee representatives who indicated data sheets will be revised to ensure that after performance of the test, check-offs will be required to indicate the SGTS tested has been returned to standby readiness. The inspector noted licensee representativcs to be revising the data sheet to reflect same (50-219/79-23-04).
b.
Laboratory Tests
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i The inspector reviewed the results of laboratory analysis of standby l
gas treatment system charcoal.
The analysis performed to meet the requirements of Technical Specification 4.5.K, Standby Gas Treatment System, Section 1.a.(2), had been identified during a previous inspec-tion (Inspection 50-219/79-18), as having not been performed as of I
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November 1979.
The test reviewed was dated December 3,1979.
The inspector review indicated testing criteria and test condition ap-peared to have been met including test results, however, several anomolies in the test data were noted.
These included:
test method referenced and sample size used.
As a result of the above, licensee representatives submitted a corrected laboratory report.
The revised lab report dated January 3,1980 appeared to meet all requirements of T.S. 4.5.K.1.a.(2).
Additionally, the licensee indicated procedures addressing the above test will be established and implemented prior to the next scheduled test (50-219/79-23-05).
c.
Air Distribution Tests Technical Specification Section 4.5.K requires that the capability of each Standby Gas Treatment System circuit be demonstrated by, among other tests, testing to ensure air distribution is uniform within +20%
across the HEPA and charcoal filters.
The inspector attempted to locate licensee test data to verify compliance with the above surveillance requirement.
The inspector noted, through review of related surveillance test data and discussicns with licensee representatives, that no air distribution measurements had been completed as of December 19, 1979. The inspector expressed concern with regard to the above and was later presented an internal licensee memorandum regarding the above.
The memo dated April 13, 1978 indicated the licensee has discussed the above with individuals involved with the development of the associated ANSI testing standards.
The inspector noted the memo to indicate action should be taken to remove this requirement from the Technical Specifications as it does not apply to facilities licensed prior to ANSI N510,1975, Testing of Nuclear Air-Cleaning Systems.
The inspector noted that as of December 19, 1979, no technical specification change request had been submitted to relieve the licensee of this testing requirement.
The inspector indicated, that pending further review and discussion with NRC Licensing personnel, this item is unresolved.
(50-219/79-23-06)
7.
Planning and Preparation The inspector discussed the licensee's planning and preparation in the area of Radiation Protection for the outage scheduled to begin January 5,1980.
The discussions, held with licensee Radiation Protection representatives, addressed the areas of:
training; supplies, contamination control; use of shielding; utilization of contracted radiation protection support personnel; whole body counting and other areas pertaining to radiation protection.
The discussions indicated the following:
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The licensee is preparing instructions for radiation protection tech-
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nicians. The instructions will address each major job undertaken during the outage and will provide the involved technician with pro-cedures, drawing and necessary information to assure job familiarity.
The inspector reviewed several job instructions and noted same to contain the above information.
Approximately 43 contractor radiation protection technicians will be
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utilized by the licensee during the outage.
Licensee representatives indicated 23 of the tecnicians will meet ANSI N18.1 (1971). Selection c'
fraining of Nuclear Power Plant Personnel Section 4.2.2, techni-cian requirements.
The licensee representatives indicated contractor technicians not meeting the above requirements will not be utilized in responsible positions.
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The licensee has ordered or has received additional radiation monitor-ing instrumentation including: 90 ion chambers (range to 1000 R/hr);
40 count rate meters and probes (pancake GM). Additionally, the licensee indicated 30 alarming dosimeters have been ordered for use.
The licensee has obtained an instrument calibrator for calibration of the above containing 161.4 curics of Cs-137.
8.
Solid Radioactive Waste The inspector reviewed solid radioactive waste analysis and shipping docu-mentation for the period January 1978 through November 1979. The inspector also observed and reviewed a radioactive waste loading operation on December 10, 1979.
The inspector reviewed the above and the overall licensee radioactive waste handling against the following:
IE Bulletin 79-19, " Packaging of Low-Level Radioactive Waste for
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Transport and Burial", dated August 10, 1979.
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IE Circular 78-03, " Packaging Greater than Type A Quantities of Low
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Specific Activity Radioactive Material for Transport", dated May 12, 1978.
10 CFR Part 71, " Packaging of Radioactive Material for Transport and
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i Transportation of Radioactive Material Under Certain Conditions".
49 CFR Parts 100 to 199, " Transportation".
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South Carolina Radioactive Material License No. 097.
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a.
Shipment Documentation 10 CFR 71.62, " Records" requires in part that the licensee shall maintain for a period of 2 years after its generation, a record of each shipment of more than a type A quantity of radioactive material as defined in 71.4(q), in a single package, showing were applicable, the results of the determinations required by 71.54. Additionally, 10 CFR 71.62 requires the licensee to maintain during the life of the package to which they pertain, sufficient quality assurance records to
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furnish evidence of the quality of packaging components which have safety significance, and of services affecting quality, including the results of determination required by 71.53.
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10 CFR 71.54 Routine Determinations, as referenced above, requires
that prior to each use of a package for shipment the licensee shall ascertain that the package satisfies the applicable requirements of Subpart C, Package Standards, of this part and has determined, among
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other items that:
(a) the packaging has not been significantly
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damaged...(c) the closure of the package and any sealing gaskets are present and are free from defects...and (i) the package has been loaded and closed in accordance with written procedures.
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Subpart C, also referenced above, addresses general standards for all packaging including:
proper package material and construction, lift-ing devices and tie-down devices.
The inspector reviewed shipping records for the shipments denoted above and also reviewed the documentation associated with those licens-ee shipments identified as discrepant during inspections conducted by Scuth Carolina officials at the licensee's contractor burial site located at Barnwell, South Carolina.
The discrepant shipments noted and reviewed were:
Curie Content Principal Date Bax. in.
Transient Package Shipment No.
Shipped One Package / Total Group Utilized OC-1046-79 4/17/79 Laundry /1.9 III HN-100 S1 OC-1050-79 4/10/79 13.9/13.9 III HN-200 OC-1057-79 4/30/79 1.1/1.1 III HN-100 S1 OC-1061-79 5/14/79 2.16/2.16 III NN-100 S1 OC-106-79 7/3/79 0.6/0.6 III HN-100 S3
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Inspector review of the above shipments indicated radiation and con-tamination limits were within limits delineated in 49 CFR 173.393.
" General Packaging and Shipment Requirements" and 49 CFR 173.397,
" Contamination Control". The inspector also noted the package to be appropriate for the quantities of radioactive material shipped.
During review of documentation associated with the shipments, the inspector noted no documentation to be availab:e to verify that the routine and preliminary determination required prior to use of a package were performad as required.
Specifically, no records, required to be maintained per 10 CFR 71.62 were available to indicate that the following determinations were performed:
(1) Routine determinations required prior to each use of a package as specified by 10 CFR 71.54.
Specifically, determinations that:
the package has not been significantly damaged and the closure of the package and any sealing gaskets are present and are free from defects; and the package has been loaded and closed in accordance with written procedures.
(2) Routine determinations required prior to each use of package to ascertain that the package with its contents satisfies the appli-cable requirements of subpart C, package standards, including:
tie-down devices; lifting devices; and package construction to preclude chemical, galvanic or other reactions with package contents.
(3). Preliminary determinations required prior to the use of a package as specified in 10 CFR 71.53.
Specifically, determinations that there are no cracks, pinholn, uncontrolled voids or other defects which could reduce the efscciveness of the packaging.
The inspector noted that notwithstanding the above shipments, the following shipments contained a greater than Type A quantity of radioactive material in a single package and were shipped from the licensees facility without record of the above determinations being performed:
Transport Date Shipment No.
Curie Content Group Shipped 0C-1018-79 17.78 III 1/30/79 OC-1025-79 8.65 III 2/21/79 OC-1009-79
'7.56 III 2/14/79 0C-1073-79 35.34 III 7/23/79 l
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The inspector indicated to licensee representatives, that failure to maintain records of preliminary and routine determinations of radio-active shipments containing more than a Type A quantity of radioactive material in a single package constitutes noncompliance with 10 CFR 71.62. (50-219/79-23-07).
The inspector noted the licensee to indicate that quality assurance records required to be maintained for the life of the package as specified in 10 CFR 71.62(c) were not available for review. The records, documenting evidence of package component quality was, as indicated by licensee representatives, available from the licensee's offsite organization.
The inspector indicated these records would be reviewed during a subsequent inspection. (50-219/79-23-08)
b.
Shipment Review 10 CFR 71.3, " Requirement for License," requires that no licensee subject to the regulations in this part shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed material except as authorized in a general license or specific license issued by the Comission, or as exempted in this part.
10 CFR 71.12 establishes a general license for persons to deliver licensed material to a carrier for transport.
The license is issued to persons having a quality assurance program whose description has been submitted to and approved by the Commission as satisfying the provisions of 571.51 and provided the applicable license condition of paragraph (a), (b), or (c) of 71.12 are met.
Additionally, IE Circular 78-03 specifically addresses licensee adhe-rence to the general license conditions of 10 CFR 71.12 for those shipments containing low specific activity (LSA) material in excess of a Type A quantity.
The inspector reviewed the loading and closure of Radioactive Waste Shipment No. 1148-79 on December 10, 1979.
The shipment, containing dewatered resin in liner No.110-79, was subsequently shipped off-site for burial.
The inspector review of the shipment encompassed the above general license, and previously referenced regulatory requirements and licens-ee adherence to the following licensee procedures:
Administrative Procedure No.101.3, Rev. O, Shipment of Radioactive
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Materials for Offsite Burial, dated 11/14/79.
Operations Procedure No. 351.10, Rev. O, Packaging Radioactive
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Wastes for Shipment to Offsite Burial Sites, dated 11/14/79.
Health Physics Procedure No. 912.1, Rev. O, dated 9/17/76.
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The inspector review of the above shioment and discussions with radio-active waste representatives indicated the following:
(1) The licensee has received Commission approval of the Quality Assurance Program for Radioactive Material Packages. The approval, No. 0355, dated November 20, 1979 applies to activities conducted under the applicable criteria of Appendix B of 10 CFR Part 50. The program is to be executed by February 1,1980.
(2) The responsible licensee individual in the area of radioactive waste transport had recently been assigned the additional duties and as a result was not aware of the informaticn transmitted in IE Circular 78-03.
(3) The shipment No. 1148-79 contained c quantity of LSA radioactive material in excess of a type A quantity and was therefore required to be delivered for transport in accordance with 10 CFR 71.12.
The inspector review indicated the shipment, No. 1148-79 was delivered for transport on December 10, 1979 without the licensee meeting license condition 71.12(b)(1)(1) in that the licensee did not have a copy of all documents (i.e., drawings) referred to in the certificate of compliance issued by the Commission's Director of Nuclear Material Safety and Safeguards. These documents included all drawings associated with certificate of compliance No. 9089.
The inspector also noted during review of shipment records that numerous shipments were delivered to a carrier for transport by the licensee without meeting the above license condition.
These include shipments associated with certificates of compliance Nos. 6574, 9079 and 9080.
Contrary to 10 CFR 71.3, on December 10, 1979, the licensee delivered licensed material to a carrier for transport and did not have a specific license for such delivery.
In addition, the licensee did not fulfill the requirements for a general license in that he did not have a copy
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of the documents called for in the certificate of complince (several drawing as referenced in the certificate of compliance). The inspector noted that the above constituted noncompliance with 10 CFR 71.3 (50-219/79-23-09).
c.
Solidified and Dewatered Waste Surveys 10 CFR 20.201, " Surveys", defines a " survey" as an evaluation of the radiation hazards incident to the production use, release, disposal or presence of radioactive materials.
Paragraph (b) of 20.201 requires each licensee to make surveys as necessary for him to comply with the
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regulations in this part.10 CFR 20.301, " Waste Disposal" specifies that no licensee shall dispose of licensed material except by transfer to an authorized recipient.
20.301 permits transfer to persons autho-rized to receive licensed material as provided in 10 CFR 30.
10 CFR 30.41 permits transfer of byproduct material to persons authorized to receive such material under terms of an agreement state license.
The inspector reviewed the licensee's radioactive waste burial con-tractors agreement state license.
The license, South Carolina Radioactive Material License No. 097 authorized, by license condition, the burial contractor to receive solidified waste containing no greater than 1%
free standing liquid by volume.
The inspector questioned licensee representatives as to what surveys i.e., evaluations were performed to ensure radioactive waste requiring solidification was in fact solidified and contained no greater than 1%
free standing liquid prior to leaving the licensee's site for burial.
The inspectors questioning indicated that as of December 10, 1979, no surveys were performed by the licensee to ensure radioactive waste transferred to the burial contractor did meet the above license condi-tion.
The inspector noted no documentation or other records available to indicate the above surveys were performed.
The inspector indicated to licensee representatives that failure to perform surveys, i.e., evaluations as necessary to comply with the requirements of 10 CFR 20.301 constitutes noncompliance with 10 CFR 20.201(50-293/79-23-10).
9.
Licensee Action on IE Bulletins The inspector reviewed licensee actions taken with respect to IE Bulletin No. 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial.
The review encompassed items addressed in licensee bulletin re-sponse letter dated September 24, 1979 and included:
document control; radwaste personnel organization; training; audits and procedures, a.
Document Control The inspector reviewed document control and distribution of the follow-ing documents with respect to the requirements of 10 CFR 50, Appendix B,
" Quality Assurance Criteria for Nuclear Power Plants and Fuel Reproces-sing Plants, Criteria VI, " Document Control".
10 CFR 20, " Standards for Protection Against Radiation"
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49 CFR Part 100 to 199, " Transportation:
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South Carolina Radioactive Material License No. 097
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Barnwell Site Disposal Criteria dated December 1,1979
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Applicable package certificates of compliance
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Radioactive Waste Shipping Procedures
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The inspector review indicated latest revision, South Carolina Radio-active Material License, Burial Site Criteria and Certificates of Compliance were on site along with current NRC and DOT regulations.
However, controlled copies of these documents were not being distri-buted to the location of use specifically radioactive waste operations.
The inspector discussed the above with licensee representatives and noted same to indicate that the individual currently supervising this area was recently appointed to this position and as a result had not been placed "on distribution" for the above.
The inspector noted the licensee was in the process of assuring the individual received dis-tribution associated with radioactive material shipping and disposal including applicable procedures.
The inspector indicated distribution of the above documents would be reviewed during a subsequent inspection (50-219/79-23-11).
b.
Radwaste Organization The inspector reviewed the radioactive waste handling organizational structure.
The review indicated a Radioactive Waste Supervisor has been appointed to be responsible for processing of waste, handling and shipping of waste from radwaste facilities.
The inspector noted a second indivi-dual is to be appointed to report to the Radwaste Supervisor.
This individual will be responsible for assuring that all waste, including laundry, is shipped in accordance with applicable regulations.
The inspector indicated additional review of this area will be con-ducted upon final selection of the individual responsible for meeting applicable regulations.
In the interim, the Radwaste Supervisor will assure all waste leaving the Radwaste Facilities will be shipped in accordance with applicable regulations (50-219/79-23-12).
c.
Audits The inspector reviewed licensee Quality Assurance Audit No. 79-04, Health Physics and Operations Radioactive Material Packaging dated
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March 7, 1979. This audit was submitted by the licensee to meet Action Item 8 of IE Bulletin 79-19, dated August 10, 1979.
The audit review included audit findings, plant management response and auditor follow-up.
The inspector reviewed the audit findings with respect to the six Action Items required to be addressed by the licensee as specified in IE Bulletin 79-19 Action Item 8.
The inspector review and discussions with licensee QA representatives indicated that the six Action Items appeared to have been addressed, however, the items did not appear to have received a thorough review as had been the intent and purpose of 1 tem 8.
The inspector noted the following areas did not appear to be addressed in sufficient depth to ensure the licensee was meeting the intent and purpose of IE Bulletin 79-19 including; Document Control and Document Adequacy including: use of current
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NRC, 00T and Agreement State License Regulations; adequacy of Radioactive Waste Handling and Shipping procedures and use of and
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control of latest revision Certificates of Compliance Radwaste Personnel Organization and qualifications of same
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Training and retraining of personnel involved in transfer, pack-
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aging and transport of radioactive material Additionally, the inspector noted the audit did not appear to address licensee compliance with waste contractor Agreement State License Conditions including applicable Site Disposal Criteria.
The inspector discussed the above findings with licensee representa-tives and expressed concern with same.
As a result, licensee repre-sentatives indicated an indepth audit of radioactive waste operations will be conducted during the first quarter of 1980.
The inspector indicated the above audit would be reviewed during a subsequent in-spection (50-219/79-23-13).
c.
Procedures The inspector reviewed the following procedures detailing radioactive waste processing, handling and shipping.
The review encompassed Technical Specification 6.8 requirements, and overall procedural adequac.
Procedure No.
Title Rev. No.
Dated 101.3 Shipment of Radioactive
11/14/79 Materials for Offsite Burial 351.4 Solid Radwaste Operating
6/13/79 Procedure 351.10 Packaging Radioactive Wastes
11/14/79 for Shipment to Offsite Burial Sites 912.1 Shipment of Radioactive Material 0 9/17/76
- 912.2 Receipt of Radioactive Material
8/20/76
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The inspector discussed the above procedures with licensee radioactive waste and radiation protection representatives.
The inspector noted licensee representatives to be in the process of revising shipping and handling pro-cedures. The inspector review indicated the revised procedures will include appropriate check-offs and verifications of package integrity prior to shipment of radioactive material (50-219/79-23-14).
10. Training The inspector reviewed the licensee's training of contractor and permanent staff Health Physics Technicians.
The review was prompted by and was a follow-up to deficiencies identified by an inspection conducted during October and November of 1979 (Inspection 50-219/79-18).
The review indicated the licensee has established a formal training program for radiation workers as defined in Procedure 915.6, Rev. O, Training in Radiation Protection, dated July 5,1979, however, this procedure also addresses training and retraining of health physics technicians in a very limited scope.
The inspector noted that other than the above no other formal documented training or retraining program was in place to assure licensee health physics technicians were receiving training and retraining on a scheduled basis in documented topics.
The inspector noted the licensee to have given two training programs to Radiation Protection technicians however the frequency of the training was not documented.
l The licensee has indicated in a letter dated January 4,1980 that a formal
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training program for Radiation Protection Technicians will be established within one month of the end of the 1980 outage (approximately April 1980).
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The inspector noted the licensee to indicate that the above program will include: procedures; lesson plans; examinations; acceptance criteria and retraining requirements.
Additionally, the inspector noted the licensee to be in the process of rewriting radiation protection technician job descriptions to encompass ANSIN18.1(1971) qualifications.
The inspector indicated the above will be examined during a subsequent inspection (50-219/79-23-15).
11.
plant Tours The inspector toured the controlled areas initially upon arrival and at various times during the inspection.
The inspector performed radiation intensity measurements where necessary to verify licensee compliance with the requirements of 10 CFR 20.203(f), " Caution signs, labels, signals and controls".
During the tours, the inspector also noted radioactive and con-taminated material appeared to be adequately labellea and controlled.
The tours also indicated High Radiation Areas were being controlled in accord-ance with Technical Specification 6.13, High Radiation Area.
No items of noncompliance were observed in this area.
12.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations.
One unresolved item is discussed in paragraph 6c.
13.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on December 19, 1979.
The inspector summarized the purpose and scope of the inspection.
The licensee representatives made the following comments:
with regard to New Radwaste Building Effluent releases, all previous
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releases will be reported by March 30, 1980 with regard to Technical Specifications addressing the operating of
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and effluent releases from the New Radwaste Building, a submittal of proposed Technical Specifications will be made by March 1, 1980 with regard to radiation protection technician training, a formal
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program will be established and implemented by approximately one month after the 1980 outage (approximately April 1980)
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