IR 05000272/1979031
| ML18081B221 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/04/1980 |
| From: | Nimitz R, Stohr J, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18081B215 | List: |
| References | |
| 50-272-79-31, 50-311-79-36, NUDOCS 8003190975 | |
| Download: ML18081B221 (11) | |
Text
Report N U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 50-272/79-31 50-311/79-36
Region I
.
50-272 Docket. No...... 5
- !0~31
+.,11--_
__ N _ DPR"-70 p *
- t 1_cense: o *. CPPR 53 r10r1 y ------
c BT Category -------
Licensee:
Public Service: Electric and Gas Company 80. Park* Place Newark,.. New, Jersey 07101 Faci 1 i ty. Name:
Salem>Nuc*lear Generating Station,. Units l and. 2 Inspection at:: Hancocks*.Bridge, New-Jersey, rnspectfon conducted:*
November* 13-15, 1979 Inspectors:
..._,,f_;_ J1. ~
Approved by::
L.,. H*. Thonus,_ Rad.iation Specialist R;:t.~ /\\]~-
R.- l., rtimitz, Radiation Specialist*
(Intern)
Inspection-Summary:*
date. signed
. l2\\\\:i\\7~
date sig_ne da:te, signe Ins ection on November* 13-15, 1979 Combined Ins ection Re art No and 50-311/79-36.
Areas* Inspected:
Special, unannounced. inspection by regional based inspectors of the actions taken by the-licensee in response to IE Bulletin No. 79-19,
"Packaging of Low-Level Radioactive* Waste for Transport and Burial", inc.luding:
document control and adequacy of document review; Radioactive waste management; personnel organization; audits; radioactive waste solidification; and follow-up on previous enforcement actio The inspection involved 33 inspector-hours on site by two NRC regional based inspector Results:
Of the four areas inspected, no items of noncompliance were identified
. in three area One item of noncompliance was identified in one area (Infraction
- Failure to.provide document control and failure to provide adequate procedures in accordance with 10 CFR 50, Paragraph 4.)
Region I Form 12 (Rev. April 77)
- DETAILS
- Persons Contacted C. HoTcomb,. S'ite: Supervisor,. Chem - Nuclear
- B'. Leap,.. Statiorr QA Supervisor..
- M. FL Metcalf,. QA Engineer
- L.. K. Miller,.. Station Performance* En.gineer
- N. L. Millis, Health Physicist F. Robertson,. Senior Maintenance Supervision
- R ~ Sil vero,. Assistant to Manager
- S.. Skabicki,. QA Staff Assistant
- J*~* C. Stillman,. Station QA Engineer
- R *.. L. Swetnam,.. Senior Performance Supervisor
- 'J *. M*~ Zupko, Jr., Chief Engineer
- Denotes. those-persons present at. the, exit interview on November*
15,. 197 The inspectors also interviewed other licensee employees including members of the Health Physics staff (station and contractor), and certain reactor operations and. maintenance personnel_
Z~
Licensee Acti.on on Previous Inspection Findings
{.Closed). Noncompliance. (272/79-07-0l). Fa.ilure to* meet general license
- requirem~nts. prior to shipment of non-exempt. fiss.ile materiaL. The* in-spector reviewed: licensee actions:; taken as addressed in licensee* response Tetter dated September 20,. 197 To preclude* recurrence,. the l i censee: has incorporated inf'ield procedure change: P-I, dated September 12, 1979, to Refueling* Instruction I-2.7.6,.
11 New Fuel Transfer and Shipmentn, Rev. The prOcedure change incorporates. 10 CFR.7T.12(b) general license: require-m~nts~
- *
- *
J...
Li'censee Audits The:: licensee.. s corporate: Quality Assurance Department (QAD) conducted an audit of* the operations; within the* scope* of IE Bulletin 79-1 The audit,.
No*.. M:-79-14,. conducted September-2.4-27, 1979 encompassed Sal em Generating Station compliance with*:
IE Bulletin 79-19, 10 CFR 71,. 49 CFR 170-179,.
station procedures and station technical specifications. This audit was a bulletin requiremen A review of licensee audit findings, plant management response and auditor follow-up was conducte The following was noted:
..
. 3
- *
the audit included an exit meeting (September 27, 197g) to apprise plant personnel of the finding an audit report, No. M-79-14, dated October 17, 1979-was prepared and distributed ona open*. item required written response within 30 days mechanisms for' follow-up and escalation of item finding were iff place The: inspector review indicated the* 1 i censee has included the quality assurance of shipping packages for radioactive material in the quality assurance program criteria. submitted in accord with 10 CFR 50, Appendix B, 11Quality Assurance Criteria for* Nuclear Power Plants and* Fuel Reprocessing Plants
- The inclusion was made in lieu. of the submittal of a separate. quality assurance program covering quality assurance for shipping packages for radioact.ive
. material as required. by 10 CFR 71. 5l(a)..
The inspector noted the 10 CFR 50 Appendix B submittal is. permitted by 10 CFR 71.51 (d).
.
The 1 icensee audit reviewed, indicated revisions. of the quality assurance audit activities are necessary to assure complete audits in the areas of:* radioactive. waste: packaging,. handling 1shipping and* the-' general requirements* of 49* CFR 100 to 199 11Transportation
Tha inspector discussed with licensee quality assurance representatives the purpose and scope of audits in the areas of radioactive waste packaging, handling and shippin The inspector noted the licensee's Operational QA Program Procedure AP-lT to implement the 10 CFR 50 Appendix B QA criteri The inspector indicated AP-17 will be reviewed at a later date to assure licensee audit revision recommendations have been incorporated (272/79-31-01; 311/79-36-01). Document. Control and Adequacy of* Document Review 10 CFR 50, Appendix B, 11Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing' Plants 11 specifies-, in Criteria Vf, 11Document Control",. that measures sha lT be established to control the-issuance of documents such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting qualit The document control measures shall assure that documents, including changes, are* reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performe *
The licensee implements Criteria.VI at Salem Nuclear Generatfog Station via Quality Assurance Manual Instruction QAI 6-l, Rev. 0.,
"Document Control 11 and Salem Operational QA Program Administrative Procedure (AP)
17~ Rev. 5, "The Electric Production Department Quality Assurance Program at Salem Generating Station 11, Section 6. o~< II Document Control. II a*.
Document Centro l Quality Assurance Manual Instruction QAI 6-1, "Document Control",
states in part that "all PSE&G organizations conducting quality-related activities shall docu~ent measures to control documents (and changes thereto) which prescribe activities affecting quality. These measures shall provide for the following:...,
control of obsolete and superceded documents, availability of documents at locations where the activity is being performed and use of* latest revision documents".. Additionally, Salem operational QA Program procedure AP-17, section 6.5,. "Requirements"
. states in part that, "document control measures shall include provisions for means of ascertaining that proper documents are being; used.
The* inspector reviewed the contro*l and di stri bu ti on of the
. following documents with respect to. the. above:
TO: CFR Part 20,. "Standards for Protection Against Radiation" 49~ CFR Part 100 to 199, "Transportation" South Carolina Radioactive Material License No.. 097 applicable* package Certificates of Compliance Rael Waste Shipping procedures..
The: inspector* review indicated the. following:
(T)
As of November 15, 1979 no up-to-date* copy of 49 CFR Part TOO to 199~~_(DOT Regula*tfons) was on sit *.
!
(2) approximately two year old copies of 10 CFR 20 and 49 CFR 100 to 199 were in use at the field location where radioactive waste activities were being performed.
(3)
the two year old copies of 10 CFR 20 and 49 CFR 100 to 199 were being used to revise current packaging, handling and shipping procedures (4)
rio formalized method of document control was inplace to assure appropriate distribution and use of current revision burial ltcense and package certificate of compliance. documentation,
. i nc:l udi ng. packag.i ng drawing The inspecto~discussed the above findings wtth licensea representatives and expressed. concern.with same~ Additionally, the inspector noted licens~a response. to It~m l of IE Bulletin *79-19, "Packaging of Low:--Level Radioactive Waste* for Transport: and Burial'.' to indicate that.a current set of applicable NRC and DOT regulations was maintained at Sale Inspector review noted one controlled copy of NRC regulations, 10 CFR 20, "Standards. for Protection Agai'nst Radiation,u was on stte,.. however, this copy was maintained in the*
QA office and it and its changes and revisions were not. distributed to the*
1 ocati on of use, i.e.. Hea 1th Physic With respect to DOT regulations, the inspector noted copies of the. appli"cabTe: regu.lations to. be* on order, however,.
these copies were* non-controlled,. i.e. no method... was in place to assure updating of samee such as. through. use of Federal Register* or DOT mailing*
list~ etc. As indicated above, the latest copy of DOT regulations on site was approximately two: years al The inspector* indicated document di stri but ion will ba reviewed in a subsequent inspectio * Adequacy of Document Review
Qua*l ity Assurance Manua T Instruction QAI S:~l. "Document Contra 1
,
discussed above, a 1 so requires that measures. shall be provided for the
"coordination of interfacing documents tO" preclude conflicts and omissions."
The* inspector reviewed the. following documents i..e.,. instructions and procedures with* respect to the above:
Maintenance Procedure M7A'~ Rev. 2, "Solid Radwaste Baling Station (Compactor)"'" dated. January 22,. 1979
Ma.intenance Procedure M78, Rev.. J,. "Sol id.. Radwaste: Drumming Sta ti on,n dated; March 28, 1979 Maintenance Procedure.M7C., Rev. 1, "Filter Handling System", dated March l, 1979 Maintenance Procedure M7F, Rev. 0, "Shipping and Receiving of Potentially Contaminated/Contaminated.Laundry" dated September lO, 1979.
Maintenance Procedure M7E, Rev. 2, 11Radioactive Solid Waste Shipment
,
dated September 26, 1979 Radiation Protection Instruction No. PD-15.T.004, Rev. 3, 11Shipment of Radioactive Material
, dated.September 11, 1979 Operating* Instruction II.-ll-3.7,. Rev. 0,.
11Chem Nuclear Demineralization
. System - Normal Operation 11 dated December 26, 1978
- The. following items were noted to be omitted from the above procedures established by.the licensee to ensure radioactive waste is shipped and disposed of tn accordance with NRG, DOT and burial site requirements:
(1)
Burial Site limitations including:
percent of cask volume containing free-standing water limits for transuranics limits for toxic chemicals limits on percent absorbed oil (2) Compliance with Applicable Shipping Cask Certificates of Compliance incl ud.i ng :.
total weight heat loading wood. shoring (where necessary)
securing o~ drain lines and access plugs (3)
Specific instructions for maintenance of exclusive use shipments to ba provided to shippe (_4)
Loading instructions* for LL-50-100 shipping cask.
.*
The inspector discussed the above with licensee representati.ves and expressed concern with overall radioactive waste handling procedures and instruction The inspector indicated that licensee procedure M7E and Iristruction 15.7004 established by.the licensee. to comply with regulatory requirements for radioactive waste shipptng both appear to cover* areas.defined tn the othe Additionally~ the inspe6tor noted that the combination. of the above procedure and. instruction would. still result in omissions'. resulting in procedurcil defi ci enci e *
The inspector indicated to licensee representatives that the above items, fatlure to adequately control and distribute documents (addressed in paragraph a), and failure to assure document adequacy (discussed above), in accordance with 10 CFR 50~ Appendix B, C~iterion VI, constitutes an item of noncompliance. * (272/79-31~02; 311/79-36-0Z) Solidificatio~ of Radioactive Waste.
A review of licensee radioactive waste solidification operati~ns was conducte The review encompassed, solidification methods, resin dewatering, boric acid waste solidificati~n and long term waste solidification plan a *.
Resin Dewatering 10- CFR 20~301,.. Waste* Disposal "General Requ.irements" prohibits disposal of licensed:. material except by transfer to an authorized recipient as prov-ided in Part 30, 40 or 70 or by disposal pursuant to 20.106, 20.30l, 20.303 or 20.30 *
The* li'censee. transfers radi cacti ve waste to a. waste: burial contractor authorized to receive same in a. license issued by an Agreement Stat The transfer is permitted as spec.ified in 10 CFR 30.41,, "Transfer of byproduct material "
The inspector reviewed the coritfactor's burial license condition specifing material that may be receive The inspector noted the current Radioactive.Material License, No. 097 Amendment No. 26, to de.fi'ne: "no. detectable free standing liquids*. as. 1% liqu.id by volume" *.
. 8 The inspector questioned licensee representatives as to how they assure free standing liquid was within the limitation specified abov The inspector was presented with and reviewed the* data of a test conducted by the licensee to determine free*
standing liquid in a dewatered* resin line The-test performed,. approximately November 6, 1979.; used a new 300 ft3 *liner containing approximately 265 ft 3 of resin and indicated approximately 5.5% volume free. standing wate The inspector noted this percent to be of the total liner volume i.e. 300 ft3 and corresponded to approximately 120 gallons of wate The inspector expressed concern with the above and discussed same with the site supervisor responsible for the demineralizer operatio The discussions indicated. that a. procedural variation, encompassing additional dewatering steps, indicated a reduction of from 5.5to1.5% free standing liquid by volum The site supervisor for the dewatering operation indicated additional dewatering steps would reduce free standing liquid to less than 1% by volum The Tiner* that had been used for the test was. reviewed: by the inspector *.
The liner, Demin No. 0923, indicated no apparent water through visual inspection of top of liner (manway).
The~ licensee, after having reviewed the above.. test data,.
suspended. shipments of dewatered resins on November 13, 197 * Tha inspector noted through discussions with licensee representatives that no further shipments of dewatered resins will be shipped until such time that appropriate measures are taken to assure less* than 1% free standing liquid is being shipped to the contractor burial site. The inspector indicated the* above measures* wi 11 be reviewe (.272/79-31-03 ;. 311 /79-36-03).
b*..
Long Term Waste.Solidification The inspector discussed with licensee representatives the current site radioactive waste needing solidificatio Th discussions indicated that at present no wastes are generated that require solidification. The licensee is able to recycle boric acid and filter and demineralize other wastes *
- The licensee indicated that a radioactive waste solidification system utilizing cement is in plac The system per discussions with licensee representatives has not been use This system is planned to be placed in operation as a long tenn solidification syste The inspector discussions with licensee representatives i nd,i cated approximately one year is needed-to p 1 ace the system in operatio.
Waste* Management Personnel Organization The licensee's response to IE Bulletin 79-19, indicated that departmental assignments currently exist for personnel involved in radioactive waste transfer, packaging and transfe The licensee's response also indicated that designation of pe~sonnel will be made in writing by January 1, 198 The inspector reviewed the waste management organization as of November 13, 197 The inspector noted that the Maintenance Department i~ involved in handling packaging and loading and to some extent assuring waste to be shipped and packaging meets the applicable requirement The inspector also noted that the Health Physics Department is also involved in packaging and shipping particularly with respect to compliance with applicable regulation The inspector review indicated' that although both departmental organizations were involved, no one single individual had overall control of the radioactive waste. handling operation This. was particularly evident in tha transfer, packaging and shipping of dewatered: resin liners for buria The inspector expressed concern with the above to licensee representatives. _
As a result the, senior perfonnance supervisor* was des,; gnated as the individual to oversee operations and' shipment of the 1 iner The
- inspector indicated that the radioactive waste, management organization to be designated on January l, 1980 will be reviewed (272/79-31-04; 31 T/79-36-04)
7.,
Additiona 1 Item Training IE Bulletin No. 79-19 requires action be taken by the licensee to provide training and p~riodic retraining for those personnel involved in the transfer, packaging and transport of radioactive materia *
--
The inspector reviewed the licensee's bulletin response dated September 25, 1979, with respect to the abov The inspector noted that the licensee has committed to the development of a supplemental training program to encompass the above by January l, 198 The training-program will be implemented_. by April l, 198 (272/79-31-05; 311/79-36'-05) *- Review of FiTte~ Replacement (June 197~)
A: complaint regarding.working conditions at Salem*- Unit Twas received by the Occupational Safety and Health Administrati'on and subsequently refered_ to NRC Region I for actio The inspector reviewed the. job conditions delineated in Radiation Exposure Permit (REP) No. 4K8 The permit indicated general radia-tion Tevels ranging from 2-4 millirem/hr. with a maximum of 80 millirem/h The permit indicited general contamination leye1s less than 1000
- dpm/100 cmZ with a maximum* of 9000 dpm/100 cm~.
The inspector reviewed the radiation exposures of those workers associated with the filter replacement tas The inspector noted one individual to have received 148 millirem whole-body exposure (obtained on another task). The other workers received_ less than 100 millirem for the entire quarte The. inspector noted the quarterly l iniit to be, 3000 miTlire The-workers performing the task received whole-body counts (WBC) to determine the presence of-an intake *. The WBCs of seven of the nine-workers were below the, minimum detectable activity (MDA) of the counter*
utilized~ The results of the remaining* two individuals were noted to be slightly above MD One individual.indicated 0.1% of a maximum permissable body burden..
No items of noncompliance were note '..
Radiation Protection Staffing The.-- inspector reviewed. the 1 icensee' s radiation protection and chemistry staffing with respect to Technical Specification requirements and Final SafetY-Ana lys-i s Report:. ( FSAR) commitments*.
The. review indicated the licensee maintains seven technicians meetjng the requirements of ANSI N18.1 (1971) "Selection and Training of Nuclear Power Plant Personnel" as specified in the above requirements* and commitment The inspector's review, however, indicated that this technician staffing was at present ass_igned to the Salem Unit 1 Facilit.,,,..
'
.*.--
- '
The inspector discussed what plans the licensee had for augmenting the staffing in this area when the Salem Unit 2 Facility becomes operationa The inspector noted through discussions with licensee representatives*
and re.view of the Unit 2. FSAR planned commitments that no increase. in staffing* was. considered: necessar The inspector expressed concern with the above to licensee representatives
- .particularly since the. additiona.l operating unit would create a substanti increase* in radiation protection and chemistry technician work loa The licensee: indicated that if the need arises, an augmented technician work
- force. would be provided* by the. use of contractor personne The inspector*
discussed the use. of contractor personnel to perform plant specific work requiring training, retraining and a somewhat higher level of plant familiarity normally not available from contractor work forces which tend to be* transient in nature, i. e *. moving from assignment to assignmen *The* fospector indicated. to. Ti censee.* representatives. that this area. will be reviewed ata subsequent inspectio Additionally, the. inspector indicated this-matter-would be addressed with the NRC (Office of Nuclear Reactor Regulation).
(50-311/79--36-06)
9*..
Exit Interview The' inspector met with licensee representatives: (denoted in Paragraph 1) at the conclusion° o.f the inspection on November 15, 197 The inspector summarized the. scope-and findings of the inspection as noted in this: report..
The:.Ttcensee: representatives'. indicated. the followfng:
No further shipments of dewatered resin liners* win be: made pending rev.iew-and. implementation of measures to control free standing liquid in:* liners for* shipment (Details Paragraph* 5.a)~
-
Pendi'ng des.i gnation of waste management' personnel on January 1,. 1980, the:* senior--*performance supervisor wi lT oversee resin dewateri ng opera--
tions...
(Details. Paragraph 6).