IR 05000272/1987020
| ML18093A320 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/10/1987 |
| From: | Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A319 | List: |
| References | |
| 50-272-87-20, 50-311-87-22, IEB-79-19, NUDOCS 8708250217 | |
| Download: ML18093A320 (6) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /87-20; 50-311/87-22 Docket No. * 50-272/50-311 License N DPR-70/DPR-75 Priority Licensee:
Public Service Electric & Gas C Salem Nuclear Generating Station Units One and Two Facility Name:
Salem Units One and Two Inspection At:
Lower Alloways Creek, New Jersey Inspection Conducted:
June 29 - July 2, 1987 Inspectors:
Approved by:
Category I Inspection Summary:
Inspection on June 29 - July 2, 1987 (Combined Inspection Report Nos. 50-272/87-20 and 50-311/87-22).
Areas Inspected:
Routine unannounced safety inspection of the licensee's radioactive waste preparation, packaging and shipping progra Results:
No violations were identifie PDR ADOCK 05000272 G
- DETAILS 1.0 Persons Contacted Licensee Personnel
- L. Miller - Assistant General Manager, Salem Operation
- E: Browder - Nuclear QA Engineer
- J. Gomeringer - Technical Supervisor, Radiation Protection
- M. Gray - Licensing Engineer
- J. Trejo - Radiation Protection/Chemistry Manager Other licensee personnel were also contacted or interviewed during this inspectio.2 USNRC Personnel
- K. Gibson, Resident Inspector
- Attended the exit interview on July 2, 198.0 Previously Identified Items (Closed) Deviation (272/86-05-01; 311/86-05-01) Failure to train two QC inspectors involved in five radwaste shipments as committed in response to Bulletin 79-1 The inspector reviewed the training program, including the course outline and records of attendance for both QC personnel and radwaste operations staff and found them satisfactor This item is'close (Closed) Severity V Noncompliance (272/86-05-02; 311/86-05-02).
This item was withdrawn in USNRC Region I letter dated April 30, 1986 to the license This item is close.0 Scope of the Inspection This inspection reviewed the licen~ee 1 s solid radioactive waste (radwaste) preparation, packaging, and shipping progra In addition, routine radioactive materials shipments to various vendors who conduct analyses on behalf of the licensee were also reviewe Shipments were reviewed relative to licensee's Technical Specification, radwaste generator requirements in 10 CFR 20.311 and 10 CFR 61.55-56, and radioactive materials tran~portation requirements in 49 CFR 170-18 Organization The organization of the licensee's program for meet1ng waste generator and transportation requirements was reviewed relative to 10 CFR 20.311, 10 CFR 61 and 10 CFR 71; the commitments in the licensee's Updated Final Safety Analysis Report and Technical Specification Performance was
determined by interview of cognizant personnel, review of Administrative Procedure (AP) 29, 11 Radioactive Waste And Material Control Program 11,
Radiation Protection (RP) Procedure:
RP 902 -
11 Radioactive Waste Sampling and Classification
RP 903 -
11 Use of RADMAN" RP 904 11 Dose Curie Conversion Calculation
RP 905 -
11Transfer of Radioactive Waste to SNGS
RP 7.004 -
11Shipment of Radioactive Waste for Burial
RP 7.046 -
11Shipment of Radioactive Materials Excluding Wastes for Burial
Within the Radiation Protection/Chemistry Department the Radiation Protection Engineer oversees the solid radwaste program through the Senior Supervisor - Radioactive Material Contro Two Technical supervisors report to the Senior Supervisor - Radioactive Material Contro These individuals supervise personnel assigned to support radwaste operation Within the scope of this review, no violations were note.0 Indoctrination and Training The licensee's program for indoctrination and training of personnel involved in solid radwaste preparation, packaging, and shipment was reviewed relative to criteria and commitments in Technical Specifications, the FSAR, and the licensee's response to NRC Bulletin 79-1 During NRC Region I Inspection 86-05, February, 1986, a deviation from the commitment made to train Quality Control Inspectors in DOT and NRC requirements for providing review of radwaste packaging and shipping activities was note Subsequently, the licensee has implemented a supplementary training program for individuals with involvement in radwaste preparation, packaging, and shipping activitie The inspector reviewed the training and retraining program course outlines as well as the attendance records and the relevant qualification records for radwaste and QC personne These were found adequat This is sufficient evidence to close out the deviatio Within the scope of this review, no violations were note.0 Quality Assurance Program A Quality Assurance (QA) program is required for transport packages in accordance with the provisions of lb CFR 71, Subpart H. A commission approved QA program which satisfies the applicable criteria of Appendix B of 10 CFR 50 which is established, maintained, and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart The licensee elected to use their currently established 10 CFR 50 Appendix B QA.program to the packaging and transportation of radioactive material In addition to the general requirements of 10 CFR 50, Appendix B, specific requirements to assure compliance with 10 CFR 61.55 and 61.56 are required by 10 CFR 20. 31 Specific requirements for qua 1 i ty contra 1 of radwaste processes is also required by Technical Specification 6.13,
"Process Control Program (PCP)". Radwaste Generator Quality Control Program The licensee's performance implementing a quality control (QC)
program under 10 CFR 20.311 and Technical Specification 6.13 was determined by review of procedures and records germane to this activity and discussions with the Supervisor Radioactive Material Contro The inspector noted that samples are sent to ~ contractor fo analysis, a vendor program is implemented by incorporation into licensee's procedures and PCP, inspection hold points are utilized, and a verified computer program is used for waste classification for Sale No concerns were note.2 QC Inspection Activities The site QC organization inspects packages and shipping activitie Inspection procedures were reviewed and discussed with cognizant personne Within this review no problems were foun.3 Surveillance Activities The site QA organization periodicalJy performs surveillances of radwaste activities including Q Quarterly surveillances were reviewed and discussed with cognizant personnel.
. No concerns were noted by the inspecto. 4 Audits During the inspection, the licensee's QA department was conducting an Audit (NM 87-04) of radwaste activities. A previous audit in this area was conducted in June 1986 (NS-87-029).
The inspector reviewed the latter and discussed both with a Principal Engineer-QA Audits and the lead inspector for the audif presently being mad The audit staff included technicaJ staff or consultant.e
Within the scope of this review no concerns were note.0 Implementation In 1987 to date, the licensee made 50 shipments of radioactive materials including solid radwaste shipment Three shipments of radioactive wastes generated by Salem and 27 shipments of radioactive wastes generated by Hope Creek were reviewe Salem acts as the shipper on behalf of Hope Cree A sample of the re~aining shipments of radioactive materials were also reviewed.* All shipments were reviewed against criteria in:
0
0
0
0 CFR 20. 311 10 CFR 30.41 10 CFR 61.55 and 61.56 10 CFR 71 49 CFR 170-189 Technical Specification 6.8, 11 Procedures and Programs",
Technical Specification 6.10, "Record Retention" and Technical Specification 6.13, "Process Control Program".
Waste Generator Requirements Waste generator requirements for waste manifests and classification waste form and characterization, waste shipment, labeling and marking and disposal site license requirements were reviewed and discussed with the license No problems were note.2 Procurement and Selection of Packaging The licensee 1 s program for selection of packages was reviewed against criteria in 10 CFR 71 and 49 CFR 17 Performance against these criteria was determined by review of procurement QA audits, procedure and shipping records review, and discussions with the Supervisor - Radioactive Material Contro No violations were note.3 Preparation of Packages for Shipment The radioactive material and waste shipment packages preparation
- program was reviewed against applicable criteria in 49 CFR 172 and 173, 10 CFR 71.87, 10 CFR 30.41, and Technical Specification 6.8, 6.10, and 6.1 Performance in this area was determined by review of procedures and related records and discussions with the licensee 1.s staf Within the scope of this review, the following concern was noted:
Periodically, the licensee ships radio~ctive materials to other licensees, including vendors who provide analytical services and those from whom equipment i~ leased and may be contaminate Frequently, shipments of samples for analysis by vendors are mad These consist of liquid c6mposite and intercomparison sam~les, filter media used in 10 CFR 61 determination, HEPA samples, etc:
Typically the sample activities or concentrations are low enough to qualify them as 11 Ltmited Quantities" per 49 CFR -173.421 and are excepted from specification packaging, shipping paper and certification, marking and labeling requirement *
When evaluating a shipment to qualify.as Limited Quantity, sample activities are compared to limits in 49 CFR 173.423 (Table 7).
On March 9, 1987, Salem shipment No. 87-11 cbntaining liquid intercomparison sample was sent as Limited Quantity to a vendor la The inspector noted that.in determining thcit the shipment qualified as Limited Quantity, the information provided by chemistry to radwaste personnel was in erro The concentration was summed and provided as activity without multiplying by a corresponding volume of sampl Procedure RP 7.046; "Shipment of Radioactive Materials
. Excluding Wastes for Burial" does not. specify how this information is conveyed. from chemistry to radwaste in a format to preclude this occurrenc The inspector noted that the activity present would still qualify the shipment to be classified as Limited Quantity but stated that the procedure was weak and should be revised to preclude this from happenin At the exit interview on July 2, 1987, the licensee agreed to revise procedure RP 7.046 to preclude this problem and a potential ~is classification. The inspector stated that thi~ would be revie~ed in a subsequent inspection (50-272/87-20-01; 50-311/87-22-01).
7.4 Delivery of Package.s to Carriers The lice~see'~ procedures for deliveririg packages to carriers were
.reviewed against criteria in 10 CFR 20.311 and 10 CFR 7 Performance relative to these criteria was evaluated by review of procedures and records and discussions with licensee persorine Within the scope of this review no viol~tions were note * 8.0 Exit Interview The inspector met with licensee representative denpted in Se~tion 1 at the conclusion of the inspection on July 2, 198 The inspector summarized the scope and findings of the inspection ~t that time.