IR 05000272/1992020
| ML18096B210 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 01/15/1993 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096B208 | List: |
| References | |
| 50-272-92-20, 50-311-92-20, 50-354-92-20, NUDOCS 9301260050 | |
| Download: ML18096B210 (11) | |
Text
~ *.
U. S. NUCLEAR REGULATORY COMMISSION Report Nos. 50-272/92-20 50-311/92-20 50-354/92-21
])ocketNos. -50:272 SQ-311 50-354 Licen8e Nos._ DRP-70 DPR-75 NPF-57
-
"
REGION I
Licensee:
Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge. New Jersey Facility Names:
Salem Nuclear Generatin& Station,' Units 1 and 2 Hope Creek Nuclear Generating Station _
Inspection At:
Hancocks Brid~. New Jersey Inspection Conducted:
December 8-10 and 17. 1992
-
,
Inspector:
fZ-L ~ ~
-
-
R. L. Nimitz, C~or Radiation Specialist _
Approved by:.~- ~v-:> ~~
-
W. Pasciak, ef
_
Facilities Radiation Protection Section Areas Inmected: -Announced inspection of the radioactive waste handling, processing, storage, and transportation programs:
Areas reviewed were organization and staffing; training and qualifications; procedures and records; audits and appraisals; 10 CFR Part 61 analyses; radioactive waste handling, storage (including long-term storage), processing, and transportation.*
Findings: The inspection identified that generally very good radioactive waste handling, sfurage, processing, and transportation programs were implemented at the Salem and Hope Creek Stations. The programs were generally well managed with a good level of technical expertise -
available* t9 support. these programs. Several areas for improvement were identified. These areas were.jmproverJient in the definition and consolidation of the training program for corporate 9301260050 930115 PDR ADOCK 05000272 G
- !
,.
support personnel, improvement iri documentation and review of entrance and exit radiation surveys of radioactive waste shipments, and improvement in quality assurance of computerized radwaste shipping paper* documentation. Two unresolved items identified. The first involved
- training, relative to IE Bulletin 79-19, of contractor personnel operating liquid radioactive waste systems at Salem. The second involved* hazardous material trirlning of personnel relative to Subpart H of 49 CFR.172~
.
- \\
DETAILS
- 1. 0 *. lndividuajs Contacted Public Service Electric and Gas Company*
- V. Polizzi, Operations Manger
- M. Morroni,. Technical Manager.
- W. Schultz, Manager, Station QA
- ~* Gary, Sr. Radiati()n Protection Supervisor - Operations.
- E. Katzman, Principle Engineer..; Rad Pro Services
- M. * Prystupa, Radi~tion Protection Engineer
- J. Wray,* Radiation Proteetion Engineer - Salem
~J. * Gomeringer, Radiation *Protection Services-Staff
- W. Hunkele, Supervisor:..Radioactive Material Control T. Cellmer, Radiation/Chemistry Manger-Salem
- K. Ma7.a, Chemistry Engirieer D. Smith, Station Licensing Engineer D. Parks, Supervisor, Nuclear Training.NRC Personnel
- S. Barr' Resident Inspector - Others P. Duca, Delmarva Power
- _Denotes attendance at the exit meeting on December 17, 1992.
The inspector also contacted other licensee personnel during, the course. ()f the inspection *
- Areas Reviewed
. The following areas were reviewed during the *irispection:.
-
organi7.ation and staffing -
training and-qualification procedures and records audits and appraisals 10 Part 61 reviews includiiig waste stream analysis *
radioactive waste transportation
. *
radioactive waste handling, processing, and storage (including long term storage plans
'*
3. 0
- Or&aniz.ation and Staffing General The inspector reviewed the organization and staffing of the on-site radioactive waste storage, handling, processing and transportation organizations. The review was with respect to criteria contained in applicable Technical Specifications and licensee administrative documents including Procedure SC.RC-TI.ZZ-Oi04(Q),
- .. Organi7.ation and Administratio The inspector evaluated the licensee's performance in this -area by review of applicable documentation, discussions with cognizant individuals, and independent observation of on-going work activitie.
. Salem Station The inspector's review indicated generally very good supervisory and management oversight of radioactive waste storage, handling, processing and transportation activities. *
The inspector deteimined *that there were no organizational changes since the previous inspection that would negatively impact the aforementioned activitie No violations were identifie. 3 Hope Creek The inspector's review indicated generally very good supervisory and management oversight of radioactive waste storage, handling, processing, an transportation activities. The inspector * determined that there were no organizational changes since the previous inspection that would negatively impact the aforementioned activitie No violations were identifie Cor.porate The licensee has in place a radiation protection/chemistry services group that supports on site operations including radwaste activities. Prior to November 30,.
1992, the group reported to the General Manager - Site Services. Effective that date, the group reports to the General Manager - Operations Suppor The organizational reporting change was made to, among other matters, strengthen.
organizational accountability and provide additional support to station operation No negative impact of the change was identifie **
No violations were identifie. Trainin& and Qualifications 4.1 * General (Salem~ Hewe, Creek and Coiporate Personnel) The inspector reviewed the trafuing and qualification of individuals involved with the storage, handling, processing, transportation, and generation of radioactive waste. The review was with respect to criteria contained in IE Bulletin No. 79-19, Packaging of Low-Level Waste Radioactive Waste for Transport and Burial, dated August 10, 1979..
The inspector reviewed organizational charts and shift manning schedules and selected for review those individuals involved with the aforementioned activitie The inspector reviewed the qualification and training documentation for radiation protection personnel, support personnel, and operations personnel. The inspector.
also reviewed the training and qualification of radiation workers relative to minimmition of radioactive was In addition, the inspector reviewed the personnel rotation policy to ensure personnel who periodically rotate into the*
areas of radioactive waste storage, handling, and transportation receive appropriate training on new procedures or procedure change Hope Creek The inspector's review indicated personnel received appropriate training and good continuing training efforts were on-goin No viol~tions or unacceptable conditions were note.3 Salem The inspector's review indicated generally good training had. been provided and good continuing training efforts were on-going. -
The following matters were noted:
______,_
The licensee uses a contractor to process liquid radioactive wastes. *The contractor periodically. visits the site and operates a temporary filter/deminerafu.er syste The system: 1.) constitutes the principal radioactive liquid waste processing system for the Salem Station and 2.)
generates volumes of spent demineraliz.er resins for disposa The inspector noted that the licensee was able to reduce off site disposal of resins by use of the system, a very good initiative. In addition, the system was operated in accordance with statio.n approved procedure I
However, the inspector noted that the training program for this mdividual
. was not well defuied reiative to the criteria.8pecified in IE Bulletin 79~1 This matter was con~idered an unresolved item (50-272 & 311/92-20-01). *
The* inspector noted that Salem operations personil~l receive re-training on radioactive waste system operations every-4 years. However, Hope Creek operations. personnel reeeive annual re-trainlng on radioactive waste processing systems. It was unclear as to the reasons for the differences
. iri frequenc *
'.The inspector noted that the licensee was revieWing IE Information Notice No. 92-72, Employee Training and Shipper Registration Requirements for Transporting Radioactive Materials, dated October 28, 1992.. The Notice proyided mformation relative to -training hazardous materials employees (Reference Subpart G and Hof 49 CFR). Subpart H si>ecifies re-training at lea8t every two years. It was. unclear if the 4 year frequency met the.
specifications of Subpart Hof 49 CFR Part i72 (effective July 1, 1992.)
This matter is ail unresolveditem (50-272 & 311/92-20-02).
No violations were identifie.0 Procedures (Salem* and Hope Creek)
The inspeetor reviewed the. procedures associated with the radioactive -waste storage, handling, and transportation program. The inspector reviewed these documents relative *
to criteria contained in applicable licensee administrative procedures and Technical Specification 6.8, Procedures. In particular, the inspector reviewed all changes made in these procedures since the previous inspection* in this area.*
.The evaluation of the licensee's performance in this area was based on review of procedures and records and discussions with per~nne * *
The inspector's review indicated that the procedures provided generally a very good level.
of guidance to personnel. The inspector noted that the licensee enhanced procedures to *
include suggestions contained in NRC Information Notice No. 92-62, Emergency Response Information Requirements for Radioactive Material Shipment The majority of procedures (Salem) were in their biennial review cycle..The pr~ures were being reviewed during the inspectio The following matters were brought to the licensee's attention:
The licensee's station document control procedure does not preclude expired procedures from remaining in controlled procedure volumes. Procedure RP (T)- 900-1, associated with handling of transport cask CNSI 14-190-H, had been superseded by another procedure (RP915). However, the superseded procedure_*
was found in the controlled procedure manuals at the Salem radioactive waste office area. The procedure wa.S remove *
The licensee's. procedures did not contain guidance regarding marking of
- packages, with capacity_ of 110 gallons or less, with the designation"RQ" (Reference 49 CFR 172. 324). The licensee immediately initiated actions to revise the procedure. The inspector's review. did not identify any apparent lack of proper marking of package.0 Audits and Appraisals <Salem and Hope Creek)
The inspector reviewed audits and appraisals of radioactive waste activities, including transportation, relative to criteria contained in Technical Specification 6.5, Audits, and the following administrative documents:
-
Procedure ND.QA-AP.ZZ-0018(Q), Revision 0, Surveillance of Station operations Procedure ND.QA-AP.ZZ-0020(Q), Revision 0, Quality Assurance Programs an Audits The evaluation of the licensee's performance in this area was based on review of audits,
_ appraisals and surveillances, and *discussions with cognizant personnel. In particular, Audit No.92-152, Radioactive Material Control (Radwaste), was reviewed as were numerous surveillances performed during 1992...
The inspector's review indicated an effective quality assurance program for radioactive _
waste activities, including transportation, was in plac The inspector noted that appropriately qualified individuals performed the audits and surveillances, and that detailed checklists, as appropriate, were prepared for * use during the audits and surveillance The followipg area for improvement was identified:
The licensee extensively uses the computer code RADMAN to. generate radioactive waste shipping documentation. Waste stream analysis data is input to the computer as well as other applicable information (e.g., volume of waste and waste type). The inspector noted there was no well defined process for
,
>
8 '
assuring that input data were properly entered into the computer code. The data entry overview was apparently informal. Although no apparent data entry errors were nQted by the inspector during review of output, the licensee's personnel indicated the above matter would be reviewed. * The inspector noted that the licensee was reviewing software quality assurance on a* site wide basi No violations were identifie. 0 Radioactive Waste Handlin~ and Stora&e General The inspector toured the Salem and Hope Creek Stations and reviewed handling and storage of radioactive waste. The evaluation of the licenSee' s performance was based on independent observations during station tours and discussions with cognizant personne.2 Salem The inspector's review of radioactive waste handling and storage indicated that these activities were effectively managed. The licensee had essentially eliminated any backlog of radioactive wast Storage areas were properly posted and controlled, as appropriate, relative to Technical Specification High Radiation Area access control requirements and 10 CFR 2 *
No violations or unacceptable conditions were note. 3 Hope Creek The inspector's review of radioactive \\\\'.aste handling and storage indicated these activities were effectively controlled. The inspect/r toured radioactive waste processing areas and noted good access control to extruder/evaporator areas and storage of asphalt waste dnims. All activities were essentially remotely controlled to rectuce access and subsequent personnel exposures. The inspector noted,that the licensee modified drum loading techniques to reduce radiation exposure and potential manual handling of drum No Violations or unacceptable conditions were note Sa1em/Hope Creek*
The inspector reviewed the licensee's plans relativ~ to construction of an interim on site low level waste storage facility. The inspector met with cognizant licensee personnel and discussed the plans. The following were noted:
~*
The licensee had established a Radwaste Task Force in October 1991 to review temporary storage facilitie The licensee's interim* facility will be located behind Hope Creek and measure about 266 feet by 68 feet. The facility will be equipped with" a 60 foot crane. The design will maximize robotic inspections and remote handling. _ The facility will be capable of storing five years of wast The facility could be constructed readily i_f neede The licensee's current storage capacity (associated with normal operations and expressed -
as months of storage capacity) at both *stations exceeds expected-construction time. The inspector noted that the licensee used criteria for construction and review of such facilities outlined in Generic Letter 81-38, Storage of Low Level Waste at Power Reactor Sites, dated November 10, 198 No violations or unacceptable conditions were note ' Transportation Activities (Salem and Hope Creek)
The inspector reviewed radioactive waste transportation activities (including records).
The review was with respect to criteria contained in the following:
-10 CFR 71, Packaging and Transportation of Radioactive Material 49 CFR Transportation applicable licensee procedures The evaluation of the licensee's ~rformance in this area was based on discussions with personnel and review of documentatio The inspector selected for review 1992 radioactive waste shipments and other shipments of radioactive material representative of those routinely and non-routinely shipped from the site. 'f4ese included laundry shipments, samples, asphalt drums, de-watered resins, -
filter cartridges and irradiated hardware. Curie content of the shipments reviewed ranged from millicurie to 17,400 curies. The inspector reviewed applicable documentation (including radiation and contamination survey data), Part 61 analyses, certificates of compliance, -and procedure adherenc *
"10 The following. matters were identified:
The inspector noted that the exit (out-going) radiation survey for shipment No.92-063 indicated 15 R/hr on.the cask and 2R/hr at 2 meters from the cask (Note that actual regulatory limits are 200 mR/hr and 10 mR/hr respectively.).
The licensee reviewed this matter and concluded that the survey data was for the cask liner (which was full of waste) and not the shipping cask in which the liner was inserte The inspector noted however, that the survey data had _been reviewed by at least two individuals, including at lea.St one superviso The licensee immediately brought the documentation error to the attention of appropriate individuals and informed all appropriate personnel. -
The in~pector's review of radiation survey data for an empty incoming cask (subsequently used for out-goirig Shipment No. 92-01) indicated that the cask exhibited, based on a December* 31, 1991, survey, removable s~rface contamination of up to 320,000 disintegrations per minute (dpm)/100 centimeter-squared ( cm2). Discussions with licensee personnel, however, indicated that the particular survey data was in error m that the survey was a large area contamination survey and that the average contamination level was about 800 dpm/100 cm2*
The inspector noted that 49 CFR 173.443 specifies an external package contamination limit of 22,000 dpm/100 cm2 for incoming shipments of radioactive material-and that the level may be determined by wiping an area of 300 cm2 of the surface concerned. It was unclear how the licensee resolved this
-. matter in that procedures contained no guidance regarding resolution of high levels of contamination on incoming radioactive waste shipping ca8ks or appropriate survey techniques for use in comparing to applicable Department of
- Transportation (DOT) limits. The procedure did, however, indicate that a supervisor should be contacted. Subsequent discussions with cogniz.ant personnel indicated that, at the time of receipt of the cask, an informal evaluation* was performed and average contanlination levels were found within applicable limits as discussed abov *
The licensee's personnel ~dicated the above matters would be reviewe The inspector noted that the cask used for Shipment No. 92-01 was not accessible to members of the public during transit or to the licensee's organization (except
, those licensee individuals authorized) while onsite beCause a cage was located around it. Also, a rain tarp was located over the cage. Both the cage and rain tarp were in place during transport and while onsite.
The inspector's review indicated that the transportation program was generally well managed. The licensee maintained comprehensive documentation packages for all out-going shipments. No violations were* identifie.0 Part 61 Analyses The inspector reviewed the licensee's scaling factors used for radioactive waste *
classification purposes. The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel and review of procedures. The inspector reviewed this area relative to guidance and suggestions provided in -NRC Information_
Notice No. 86-20, Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61, dated March 28~ 1986, and the NRC Branch Technical Position (BTP) on waste classification, dated May 11, 198 The inspectOr reviewed all waste streams and waste types generated by the Salem and Hope Creek Station The inspector's review indicated that the licensee established and implemented appropriate scaling factors and -that the factors were being updated in accordance with recommendations contained within the above BT *
No violations or unacceptable conditions were note *1 Plant Tours The following observations were made during tours of the station:
The inspector's tours of the station indicated that overall, housekeeping was very good and improving. The licensee was cleaning, painting and re-furbishing areas.throughout the statio Ho,pe Creek The inst>ector's tours of the station indicated that overall, housekeeping was generally very good and improvin.0 Exit Meeting The inspector met with licensee representativeS (denoted in Section 1.0) on December 17, 1992. The inspector-summarWxl the purpose, scope and findings of the inspection.