IR 05000255/1997010
| ML18067A669 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/01/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18067A668 | List: |
| References | |
| 50-255-97-10, NUDOCS 9709050224 | |
| Download: ML18067A669 (15) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved by:
REGION 111 50-255 DPR-20 50-255/9701 O(DRS)
Consumers Power Company 212 West Michigan Avenue Jackson, Ml 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Ml* 49043-9530 August 4-8, 1997 R. Glinski, Radiation Specialist Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety
- EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/97010 This inspection was conducted to review the implementation of the solid radioactive waste management and shipping program at the Palisades Nuclear Generating Plant. The inspection included review of the plant staff's implementation of and compliance with the recently revised Department of Transportation and NRC. regulations. The following conclusions were reached:
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The training, procedure revisions, and shipment preparations were implemented in accordance with the new DOT and NRC regulations. Minor errors in shipping procedures and papers indicated a lack of attention to detail by plant personnel (Section R1.1 ).
The implementation of the solid radwaste storage and shipping programs was effective, as plant staff have worked aggressively to decrease the onsite radwaste inventory (Section R2.1 ).
Determination of radionuclide scaling factors was effective in enabling the staff to appropriately classify waste and meet regulatory requirements for radioactive material shipments (Section R1.3).
The new volume reduction system was effectively utilized to accomplish further radwaste reduction over the previous system. Recent initiatives to reduce dry active waste generation have been successful, and the formation of an inter-departmental team demonstrated a strong commitment to radwaste reduction (Section R 1.4).
Plant personnel surveyed and repaired a variety of radwaste storage and processing components. However, housekeeping and material condition concerns were identified in the purification filter and demineralizer rooms during this inspectio (Section R2.1 ).
The audits, self-assessment, and field monitoring reports for solid radwaste management and shipping were comprehensive, performance-based, and identified significant issues and areas for improvement (Section R7.1 ).
- Report Details R1 Status of Radiological Protection and Chemistry (RP&C) Controls R 1. 1 Transportation of Radioactive Materials Inspection Scope (IP 86750, Tl 2515/1331 The inspector reviewed the radioactive material (RAM) transportation program, including an assessment of training and qualifications of shipping personnel, transportation of low specific activity (LSA) material and surface contaminated objects (SCO), expansion of the radionuclide list, changes in radioactivity limits, and the use of international system (SI) units.. The inspector also reviewed several transportation procedures and shipping manifests to determine compliance with new shipping regulation Observations and Findings Department of Transportation (DOT) and NRC regulations pertaining to the transportation of RAM were significantly changed on April 1, 1996. The inspector noted that the licensee's training program addressed the updated DOT and NRC regulations and was effectively implemented. Several members of the Chemical and Radiological Services (C&RS) staff successfully passed a 1996 vendor-supplied training course detailing the regulatory changes. Overall, the RAM shipping personnel were knowledgeable of the updated transportation regulation The inspector reviewed the C&RS procedures and work instructions for transporting LSA and SCO materials. The C&RS staff had revised the shipping procedures and then submitted the revisions to a RAM shipping vendor to ensure regulatory compliance. The current revisions reflected the recent regulatory revision However, several minor errors were identified in these documents which indicated a lack of attention to detai C&RS staff utilized a commercial software program for calculating various values to appropriately classify radioactive waste (radwaste) and prepare shipping papers. The inspector reviewed the shipping papers associated with two SCO shipments and verified that the determination of SC0-1 and SC0-11 were based on current value C&RS staff utilized commercial software for dose to curie conversions to determine fixed and inaccessible contamination for SCO shipments, and no problems were identified with these shipments. The inspector also reviewed shipping papers associated with representative LSA, limited quantity, and Type A shipments and verified the calculations for determining the proper transportation designatio Review of shipping data produced by the software showed that the current scaling factors were utilized by the C&RS staff. Palisades has not transported any LSA-111 material. Except for Limited Quantity and empty packages, all other shipments were conducted as Exclusive Use.
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The shipping manifests and associated paperwork contained the proper information regarding waste classification, reportable quantity, physical and chemical form, radiation levels, emergency response information, volume, weight, total activity (in SI units), the 95 % rule for listing nuclides, and were signed by authorized personne In addition, the activities of tritium, carbon-14, technecium-99, and iodine-129 for waste shipments were listed as required by 10 CFR 20, Appendix G. When applicable, the licensee utilized the equivalent of NRC Forms 540, 540A, and 541 for radwaste shipments. In accordance with NRC requirements, the C&RS staff possessed the current licenses for the various facilities to which RAM shipments were mad During the review of several shipping packages, the inspector identified one shipment with a miscalculation of RAM and one shipment where the incorrect value for plutonium content was listed. In both instances the listed amount of RAM was greater than the actual content, such that the errors were conservative. Plant personnel contacted the receivers of these shipments, informed them of the errors, and prepared corrected manifests during the inspection. These minor errors were additional examples indicating a lack of attention to detail by plant staff. Site personnel are in the process of procuring a commercial software program which will print an assembled shipping manifest and minimize the potential for these types of error Radwaste personnel possessed the current table of A 1 and A2 values for the expanded list of radionuclides to ensure that packages would not exceed their allowable quantities. The inspector independently selected A 1 and A 2 values generated from the C&RS shipping software computer (cobalt-60, zinc-65, cesium-137, rubidium-86, and several transuranics) and verified that the new values were utilized. The inspector verified that plant personnel were knowledgeable in the use of. the computer softwar Conclusions The inspector determined that the training, procedure revisions, and shipment preparations were implemented in accordance with the new DOT ~nd NRC regulations. Minor errors in shipping procedures and papers indicated a lack of attention to detail by plant personne R1.2 Storage of Solid Radioactive Waste and Radioactive Materials Inspection Scope (IP 86750)
The inspector reviewed the solid radwaste and RAM management progra Walkdowns and radiological surveys were performed of the solid radwaste and storage facilities, the various RAM storage areas, and the Temporary Radioactive Material Storage Areas, which are located outside the Radiologically Controlled Area (RCA), including the interim steam generator storage facility. The inspector also reviewed the Final Safety Analysis Report (FSAR) and other selected documents, and conducted interviews with various radwaste personnel.
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Observations and Findings Prior to shipment, solid radwaste was primarily stored in the East Radwaste Building (ERB). RAM stored in the ERB, as well as several small areas just outside the ERB, was appropriately controlled. There was no mixed low-level waste stored onsit The inspector's surveys determined that radiation postings and container labels throughout the ERB and the surrounding storage areas were appropriate. There are currently no requirements to periodically inspect the radwaste containers when the plant has access to burial facilities, but C&RS staff have discussed initiating periodic visual inspections. Continuous air monitoring and filtered ventilation were used to detect and mitigate any airborne contamination. The required personnel contamination monitor, frisker, and area radiation monitor were operable. The ERB was consistent with the FSAR descriptio The inspector identified one concern at the ERB regarding the position of a telephone within this facility. During the walkdown, the inspector observed that a telephone was mounted on the outside wall of a temporary high radiation area. Due to gamma radiation streaming from between the wall and a mobile lead shield covering the open entrance, the inspector measured a radiation dose rate of 10-12 millirem per hour (mrem/h) which was consistent with previous C&RS surveys. The inspector observed a radwaste individual use this phone, and the inspector subsequently discussed with C&RS supervisory staff whether the location of this phone was consistent with As Low As is Reasonably Achievable (ALARA) practice. Plant personnel indicated that the phone was positioned in this location since original construction. The telephone was removed during the inspectio The licensee stored low level RAM in several short-term and long-term temporary storage areas outside the RCA. The inspector observed the RAM stored in the temporary storage areas within the protected area, such as the area northwest of the Feedwater Purity Building, the Feedwater Purity Building storage area, and the North Storage Building. There was a HEPA unit and air sampler available to detect and control airborne radioactivity in the North Storage Building decontamination boot Radioactive material stored outside the protected area was located in the East Storage Building, Old South Radwaste Storage Building, and the South Pole Bar Walkdowns and radiation surveys by the inspector confirmed that the RAM in these storage areas was properly controlled, posted, and labeled. C&RS staff surveyed the RAM outside the RCA regularly and the inspector noted that the radiological surveys were conducted as required. The interim storage facility for the steam generators was well controlled and no concerns were identified.* No concerns were identified
- regarding the long-term RAM storage area located just outside this steam generator storage facility. Large pieces of contaminated concrete which came from containment during the removal of the steam generators were contained in this are The licensee had been denied access to offsite burial from July 1990 to June 1995, and had therefore accumulated a large radwaste inventory onsite. The opportunity to resume shipping radioactive waste to offsite burial facilities became available in June 1995. Since that time, the C&RS radwaste group has taken action to reduce
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the inventory of radwaste stored onsite. In 1996, the staff shipped 379.5 cubic feet of dry active waste (DAW) and 202.5 cubic feet of radwaste concentrate The following table summarizes the status of solid radwaste at the time of this inspection for 1997, including rad waste to be shipped before January 1998 (all volumes in cubic feet):
Waste Type Stored Onsite Shipped To Be Shipped DAW.8 Concentrates 59.0 55 Evaporator Bottoms 10.0 Filter media 71.0 46 Spent resin (primary)
20.0 Irradiated hardware 2.0 Spent resin (secondary).0 Stud covers.0 \\
Control Rod Drive.0 Mechanisms In addition to the above, there was 94 cubic feet of steam generator material, 190 cubic feet of contaminated lead blankets/bricks/sheets, and 860 cubic feet of upender trash presently onsite that was being held for either processing or storag In 1997, C&RS staff also shipped over 600 cubic feet of other types of waste for offsite processing and disposa Conclusions The inspector determined that the implementation of the solid radwaste storage and shipping programs was successful. In par:ticular, C&RS staff have worked aggressively in 1 996 and 1997 to decrease the onsite radwaste inventor R 1.3 Solid Radioactive Waste Classification Inspection Scope (IP 86750, Tl 2525/133)
The inspector interviewed staff, and reviewed the procedures and documentatio which controlled the sampling and analysis of radioactive waste to ensure compliance with 10 CFR 61 requirements for determining waste classification. The
inspector also reviewed the Process Control Program (PCP) and various waste classification studies conducted by vendor Observations and Findings Solid radwaste classification involved the periodic collection of samples to radiologically characterize wet homogeneous solid wastes (resins, concentrates, evaporator bottoms), DAW, filter media, and irradiated hardware. The samples were collected annually or as available. The 10 CFR 61 samples were analyzed by a vendor laboratory to quantify the radionuclides present and generate isotopic ratios (scaling factors) for quantifying the difficult to measure isotopes. Reactor coolant radiological analyses were monitored by the fuel integrity group to ensure that the current scaling factor analyses remained applicabl The inspector reviewed the most recent scaling factor determination which was conducted in February 1997. The 1997 radioanalytical analyses were very similar to data from previous years and justified the station practice of using data from waste stream samples collected over several years to generate current scaling factors. The scaling factors for fission products, activation products, and transuranics were also consistent with the industry averages for pressurized water reactor facilitie Characterization of irradiated hardware was conducted by a vendor based on data submitted by C&RS staff. These evaluations determined that the Cycle 12 irradiated hardware was primarily composed of chromium-51 (27 day half-life), and the radioactivity would decrease to less than one third the original level within one yea The inspector did not identify any concerns with the 10 CFR 61 characterization The inspector reviewed the station program to determine the radioactivity content of RAM shipments. Samples were collected by the chemistry staff for various laboratory analyses to determine the isotopic and activity content of each radwaste stream. C&RS staff conducted gamma spectrometry to quantify the key nuclides (cobalt-60 and cesium-137) designated to establish scaling factors, and these analytical results were then used to determine the radiological content of the shipment. For DAW, the radwaste staff conducted a dose-to-curie analysis using commercial software and the DAW scaling factor The inspector also reviewed the lower limits of detection (LLD) for several difficult to measure radionuclides and determined that the station was in compliance with guidance in the NRC's "Final Waste Classification and Waste Form Technical Position Papers."
c. Conclusions The inspector concluded that the determination of radionuclide scaling factors was effective, and enabled the staff to appropriately.classify waste for RAM shipment These activities met regulatory requirement ~*
R1.4 Solid Radwaste Process and Reduction Activities Inspection Scope (86750)
The inspector walked down the old and new volume reduction systems (VRS) and the associated control panels. The inspector also reviewed the operational procedure and operation logs, and interviewed C&RS and engineering staff regarding the performance of the new VR Observations and Findings The old VRS utilized asphalt as the solidifying agent. This system was in operation from the mid-1980's until 1996. The station has planned to release the asphalt VRS mixing equipment, the barrel conveyor equipment, and control panel as scrap meta In August 1996, the station began to use a new VRS (RVR-200) which utilizes paraffin as the solidification agent. C&RS staff stated that volume reduction for concentrate waste realized was greater than 80% over the asphalt system. This new VRS has been considered as a temporary modification and was therefore, not described in the FSAR or PCP. Station management have recently decided to install and operate this VRS permanently, and plant personnel indicated that it will be incorporated into the FSAR and PC The inspector observed engineering staff simulate operation of the RVR-200 and reviewed operational logs for the last nine "dumps" placed into a High Integrity Container (HIC). The logs indicated that the RVR-200 was operated within the appropriate temperature, pressure, and paraffin/waste ratios required by procedur The operators also verified that the room was under negative pressure during VRS operation. After the paraffin mixture had solidified, a visual inspection was conducted by C&RS shipping staff to look for standing water which would violate burial requirements. Any standing water would be removed by a heat/vacuum treatment to minimize the liquid conten Interviews with various staff indicated excellent overall performance, with infrequent problems of line plugging and carry over of paraffin into the condenser. Plant personnel recently identified that this VRS had generated approximately four times
- more solid radwaste than originally estimated. Review by plant staff determined that various operational changes, such as increased silica content in clean waste systems, boron reduction in the spent fuel pool, and three plant startups in 1997 caused the station to process much more wastewater (and eight more HICs) than was anticipate The RAM shipping staff stated that a number of clean items were placed into RAM bags and were then segregated from contaminated material at the ERB. This clean material consisted of such items as spray bottles, aerosol cans, and metal bracket Other clean materials were segregated from RAM at contract facilities. In the
context of the increased solid radwaste and clean material being deposited in contaminated material bags, the inspector discussed with C&RS supervisory staff regarding any plans for radwaste reduction. The supervisors responded that plant
staff had recently received training on various methods to minimize radwaste, such as restricting packing material in the RCA, maintaining clean areas, dedicated tools in the Hot Tool Crib, use of launderables, and minimizing liquid radwaste. These measures were initiated recently and have resulted in a 75% reduction in DAW generatio In an effort to further reduce generation of radwaste, the plant has tasked a multi-departmental team to develop and implement a Management Action Plan to reduce radwaste generation. This plan encompasses several measures, including training staff to reduce radwaste, evaluating the impact of high silica content on the reuse of clean water, in-series operation and optional disposal methods for steam generator blowdown demineralizer resins, and review of recommendations gathered from current industry experience and practice. To date, the in-series operation of the steam generator blowdown resins has increased demineralizer run times and reduced resin radwaste generatio Conclusions The inspector determined that the paraffin-based volume reduction system was effectively utilized to accomplish further radwaste reduction over the previous system. Recent initiatives to reduce radwaste generation have been successful, and development of further measures by an inter-departmental team demonstrated a site commitment to radwaste reductio R2 Status of RP&C Facilities and Equipment R2.1 Performance and Material Condition of Radioactive Waste Treatment Systems Inspection Scope (IP 86750)
The inspector conducted walk downs and radiation surveys of the waste gas compressor, liquid radwaste pump, and the evaporator concentrate tank rooms. In addition, a videotape of the following radwaste storage and processing rooms was reviewed:
Purification filters room (F54 A/B)
Purification demineralizer room {T-55 tank)
T-100 tank room for spent resin sluicing
T-69 tank room for spent resin storage
T-60 floor drain holding tank room
Clean wash filter room
The inspector also interviewed C&RS staff regarding maintenance of the radwaste system equipment in these room Observations and Findings The inspector verified that the waste gas compressor, liquid radwaste pump, and evaporator rooms were appropriately posted. Portions of these rooms were posted as rad.iation and/or contaminated areas primarily due to work being conducted on various radwaste system components. There were no material condition concerns beyond the work that was in progres In the summer of 1996, plant personnel utilized a robot to examine and videotape various radwaste process and storage rooms, some of which were posted as high radiation and highly contaminated areas. The videotape revealed a number of housekeeping and material condition concerns in most of these rooms. Some rusting and a significant amount of boric acid crystals were observed on the carbon steel bolts of the support bases and on various valve flanges. Since that time, station personnel have cleaned and effected repairs in several of these rooms. However, at the time of this inspection, the purification filter and purification demineralizer rooms remained in the same condition as noted on the videotape. Plant staff indicated that there were known leaks in the purification filter room. C&RS supervisors stated that a robotic survey would be conducted early in 1998 to determine the radiological conditions of these rooms, and that existing problems would be addressed during the 1998 refueling outage. The actions to address the purification filter and demineralizer rooms concerns will be evaluated during a future inspection as an Inspection Followup Item (50-255/97010-01 ). Conclusions Plant personnel had surveyed and effected repairs for a variety of radwaste storage and processing components. However, current housekeeping and material condition concerns were identified in the purification filter and purification demineralizer room Actions to address radwaste component concerns will be evaluated during a future inspectio R7 Quality Assurance in RP&C Activities R7. 1 Review of Audits and Self-Assessments Inspection Scope (86750)
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The inspector reviewed two Nuclear Performance Assessment Department {NPAD)
audits, a self-assessment, and several NPAD field monitoring reports regarding solid radvvas_te rn?n.agernent and transportation..
10 Observations and Findings The NPAD staff conducted audits with the assistance of health physics supervisors from other nuclear power plants. These audits did not identify any technical concerns with the PCP. The self-assessment was conducted by a C&RS supervisor who identified that the 49 CFR 173.203(d) requirement had not been incorporated into the revised procedures, the need for several editorial changes in the RAM shipping procedures, and several minor errors in shipping papers. The self-assessment concluded that greater attention to documentation detail was warrante The self-assessment also reviewed the status of the ERB and no problems were identified, although staff recommended that the current practice of leaving shielded lids off storage containers should be re-evaluate The NPAD field monitoring reports were based on observations of training, pre-job briefings, and spent resin sluicing activities. The various radiation protection issues identified included poor housekeeping regarding spilled resin, a sparking crane switch, poorly organized pre-job briefings, lack of procedural control for work, and lack of a timely radiological survey of a transport cask. These field reports also included several recommendations to enhance station documentation and performance, and plant staff addressed several of the issues in a timely manne Conclusions The inspector concluded that the audits, self-assessment, and field monitoring reports were comprehensive, performance-based, and identified significant issues and areas for improvemen X 1 Exit Meeting Summary The inspector presented the inspection findings to members of licensee management during an exit meeting on August 8, 1997. Plant management agreed with the finding Plant personnel did not indicate that any materials examined during the inspection should be considered proprietar PARTIAL LIST OF PERSONS CONTACTED Licensee J. Beer, Technical Support Supervisor T. Berdine, Licensing Manager E. Bowen, System Engineer W. Doolittle, Duty Health Physicist Supervisor B. Dotson, Licensing R. Henry, Radiation Services Shipping Supervisor R. McCaleb, Nuclear Performance Assessment Department Supervisor M. Menucci, C&RS Assessment T. Neal, Environmental Supervisor T. Palmisano, Site Vice President and General Manager C. Plachta, Health Physics Operations Supervisor D. Rogers, Operations Manager K. Schneider, C&RS Training Facilitator R. Simonsen, System Engineer R. Smedley, Licensing Programs Supervisor M. Parker, Senior Resident Inspector, Palisades P. Prescott, Resident Inspector, Palisades INSPECTION PROCEDURES USED IP 86750, "Solid Radioactive Waste Management and Transportation of Radioactive Materials" Tl 2515/133~ "Implementation of Revised 49 CFR Parts 100-179 and 10 CFR 71" Opened 50-255/97010-01 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSE IFI Evidence of equipment leaks and poor housekeeping in radwaste treatment rooms
C ALARA C&RS DAW DOT ERB FSAR HEPA HIC LSA NPAD PCP RAM RCA sco SI VRS ACRONYMS USED As Low As is Reasonably Achievable Chemical and Radiological Services Dry Active Waste Department of Transportation East Radwaste Building Final Safety Analysis Report High Efficiency Particulate Air High Integrity Container Low Specific Activity Nuclear Performance Assessment Department Process Control Program Radioactive Material Radiologically Controlled Area Surface Contaminated Object International System Volume Reduction System
LISTING OF DOCUMENTS REVIEWED Palisades Nuclear Plant (PNP) Health Physics Procedure No. HP 6.20, Revision 20,
"Radioactive Material Shipments".
PNP Procedure No. HP 6.34, Revision 6,. "Radioactive Material Shipments - Burial Sites Only".
PNP Procedure No. HP 2.14, Revision 17, "Radiological Survey Requirements".
PNP Procedure No. HP 2.20, Revision 9, "Radiation Safety Area Posting".
PNP Procedure No. HP 6.18, Revision 22, "Low-Level Radwaste Packaging".
PNP Procedure No. HP 6.27, Revision 3, "Low-Level Radioactive Waste Container and Storage Area Inspections".
PNP Procedure No. SOP-18D, Revision 2, "Operating the Vectra RVR-200 System".
PNP Work Instruction (WI) Wl-RSD-R-013, Revision 0, "Surface Contaminated Object Shipments".
Wl-RSD-R-001, Revision 4, "Radiological Controls and Instrumentation for the East Radwaste Building".
Wl-RSD-R-005, Revision 5, "Mixed Low-Level Waste Management Plan".
Final Safety Analysis Report (FSAR) Section 11.4.2.5 - "Radioactive Waste Storage Facilities".
FSAR Section 11.4.3 - "Radioactive Releases".
FSAR Section 11.4.5 - "System Evaluation".
FSAR Section 11.6.10 - "Radioactive Material Storage Facilities".
PNP Technical Specifications Section 7.0, "Administrative Controls".
PNP RAM Shipments96-098, 97-007,97-010, 97-021,97-022, 97-026, and 97-03 Characterization of Cycle 10 + 11 In-Core Instrument Strings at Palisades Nuclear Power Station; WMG-9609, Dated June 1996:
Characterization of Cycle 12 In-Core Instrument Strings at Palisades Nuclear Power Station; WMG-9623, Dated December 199 Engineering Analysis; Evaluation of 10 CFR 61 Scaling Factors for Palisades, EA-JLF-91-01, dated February 13, 199 ".
PNP Process Control Program, dated February 16, 199 C&RS Self-Assessment #97-29, "Solid Radwaste and Transportation", dated 8/1 /9 Nuclear Performance Assessment Department (NPAD) Audit PA-96-20, "Palisades Health Physics and Shipping and Packaging of Radwaste, dated 11 /1 /9 NPAD Audit PT-97-02, "Palisades Radiological Effluent Technical Specification and Radiological Environmental Monitoring Program", dated 3/13/9 NPAD Audit PT-95-01, "Palisades Radiological Effluent Technical Specification and Radiological Environmental Monitoring Program", dated 2/16/9 NPAD Field Monitoring Reports FM-P-96-011, FM-P-96-037, FM-P-96-044, FM-P~96-047, FM-P-96-084, FM-P-96-113, FM-P-97-013, FM-P-97-017, FM-P-97-01