IR 05000277/1979027
| ML19290D977 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/12/1979 |
| From: | Clemons P, Stohr J, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19290D968 | List: |
| References | |
| 50-277-79-27, 50-278-79-30, NUDOCS 8002290593 | |
| Download: ML19290D977 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 79-U Report No.
79-30 60-2//
Docket No.
50-278 DPR-44 License No.
npo qn Priority
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Category C
Licensee:
Philadelphia Electric Canpany 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Botton Atomic Power Station, Units 2 and 3 Inspection at:
Delta, Pennsyl/ania Inspection conducted:
October 30 - Novenber 1,1979 Inspectors:
%Md f0 hf L. H. Thonus, RadiaEion Specialist date signed
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M P. E. Clenons, Radiation Specialist datd sicfned date signed
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Approved by:
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J. P. Stohr, Chief Radiation Support date signed Section, FF&MS Branch Inspection Summary:
Inspection on October 30 - November 1,1979 (Report Nos. 50-277/79-27; 50-278/79-30 Areas Inspected:
Routine unannounced inspection by two NRC regional based inspectors of the licensee's response to IE Bulletin 79-19 including maintenance of regulatory requirements, training, audits, procedures and package canpliance. The inspection involved 36 inspector-hours onsite by two NRC regional based inspectors.
Results:
Of the five areas inspected no itens of noncompliance were found in four areas; two itens of noncanpliance were found in one area (infraction-failure to adhere to procedures, paragraph 5; and failure to maintain current procedures at the work location, paragraph 5).
Region I Form 12 (Rev. April 77)
4 002 200, q-3
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OETAILS 1.
Persons Contacted Mr. W. Barley, Engineer - Health Physics Mr. R. Costagliola, General Supervisor, QA Division
- Mr. J. Davenport, Engineer - QA Mr. G. Filson, Assistant Auditor, QA Division Mr. R. Fleischmann, Assistant Station Superintendent Mr. N. Gazda, Health Physics Support Supervisor Mr. G. Horton, Training Specialist (General Physics Corporation)
Mr. S. Kovacs, Engineer - Administration
- Mr. K. Mandl, Auditor, QA Division
- Mr. C. Mengers, Site Supervisor, QA Division Mr. S. Nelson, Training Assistant
- Mr. P. Pauly, Radwaste Supervisor Mr. H. Reynolds, Health Physics - Technical Assistant
- Mr. R. Scholz, Engineer - Chemistry
- Mr. W. Ullrich, Station Superintendent The inspector also interviewed several other licensee employees, including health physics, maintenance,.and operations personnel.
2.
Maintenance of Regulatory Requirements The inspectors reviewed the licensees methods of maintaining current regulatory requirements, including 10 CFR, 49 CFR, burial site requirements, aiid certificate of compliance requirements for shipping casks.
10 CFR The licensee maintains a copy of 10 CFR from the Superintendent of Documents, U. S. Government Printing Office as part of a subscription service.
This service includes page changes to update the licensees copy of 10 CFR as the regulations change.
This copy is maintained by the Engineer - Health Physics.
49 CFR The licensee maintains 2 copies of 49 CFR from two independent vendors.
These are subscription services with page changes to keep the volumes current as above.
These volumes are also. maintained by the Engineer -
Health Physics.
Burial Site Reouirements The licensee maintains copies of burial sites' agreement state licensees (South Carolina License #097 and Nevada License #13-11-0043-02) and a copy of the burial sites' requirements.
These documents are supplied and updated by the waste disposal vendor.
The Engineer-Chemistry maintains these document.
Certificates of Compliance In order to fulfill the requirements for a general license to ship greater than Type A quantities of radioactive materials, the licensee is required to have a copy of the certificate of compliance and all documents referred to in the certificate.
The licensees documents authorizing the use of a Hittman HN-100 cask were maintained by the Engineer-Chemistry.
No items of noncompliance were identified.
3.
Training The licensee had implemented and completed a short training course regarding waste shipments for the 3 individuals most directly involved in making and overseeing such shipments.
Topics covered included:
00T Shipping Requirements (49 CFR)
NRC Shipping Requirements (10 CFR 71)
Barnwell Burial Site Criteria and License Beatty Burial Site Criteria and License Operating Procedures:
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HP0/C0-17 Shipment of Radioactive Material 2.
HP0/CO-71A Filling, Capping, and Storage of Spent Resins 3.
HP0/CO-71C Loading of a Radwaste Vehicle 4.
HP0/CO-71C Appendix A - Loading and Closing the HN-100 and HN-600 Casks 5.
HP0/C0-71C Appendix B - Loading and Closing the HN-200 Radwaste Cask 6.
HP0/C0-71C COL - Loading of a Radwaste Vehicle 7.
HP0/CO-71D Compacting and Storage of Compacted Radioactive Trash 8.
HP0/CO-71E Determination of Heat Flux from a Radwaste Drum 9.
HP0/C0-71F Verification of Burial Site Criteria for Radwaste Shipping 10.
HP0/CO-71F COL - Burial Site Criteria for Barnwell, South Carolina 11.
HP0/C0-71F2 COL - Burial Site for Beatty, Nevada 12.
HP0/CO-71G Loading of a Radwaste T uck or Van 13.
HP0/CO-71G COL - Loading of a Radwaste Truck or Van 14.
HP0/CO-71H Packaging and Storage of Non-Compacted Radioactive Trash in LSA Containers Additionally the licensee had contracted with General Physics Corporation to conduct a training program covering the same topics for the plant helpers, auxiliary operators, assistant plant operators, plant operators, shift supervisors and shift superintendents.
This training was scheduled to be completed before January 1,1980.
A licensee representative stated that a written exam would be administered and that the retraining interval would be annual.
No items of noncompliance were identifie.
Licensee Audit
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The inspectors reviewed the licensees Audit A 79-23 which was conducted on October 8, 1979. The Audit encompassed licensee compliance with:
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burial site requirements
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49 CFR
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certificate of compliance requirements
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licensee procedures The licensees audit program includes an exit interview (held October 8, 1979) to apprise plant personnel of the findings; a 30 day written audit report; a 30 day written plant response; and reaudit of deficiencies found in the audit.
The inspectors noted that some of the audit findings had been addressed and completed and the remainder were in progress.
The licensee long term audit schedule in this area provides for a six-month audit frequency for identified problems, annual audit of chemistry and health physics, and a biannual audit of radwaste and casks.
No items of noncompliance were identified.
5.
Procedures Technical Specification 6.8.1 requires that " Written procedures and administrative policies shall be established, implemented and maintained that meet the requirements of Section 5.1 and 5.3 of ANSI N18.7-1972 and Appendix "A" of USAEC Regulatory Guide 1.33."
Technical Specification 6.8.2 requires that "Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed by the PORC and approved by the Station Superintendent prior to implementation and periodically as set forth in each document."
Appendix A of regulatory guide 1.33 (1972) requires procedures for spent resins and filter sludge handling and bailing machine operation.
10 CFR 71.54 requires that non-exempt packages be loaded and closed in accordance with written procedures. The inspector reviewed the following health physics procedures against the TS 6.8.1 and 6.8.2 requirements:
HP0/C0-71 A Filling, Capping, and Storage of Spent Resins HP0/CO-71C Loading of a Radwaste Vehicle HP0/C0-71D Compacting and Storage of Compacted Radioactive Trash HP0/C0-71E Determination of Heat Flux from a Radwaste Drum HP0/C0-71F Verification of Burial Site Criteria for Radwaste Shipping HP0/CO-71G Loading of a Radwaste Truck or Van HP0/C0-17A Responsibility for the Safe Transfer, Packaging and transport of Radioactive Material
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The inspectors examined the licensee radwaste facility on October 31, 1979 to determine the state of the licensee compliance with procedures dealing with operations of the radwaste facility.
The inspector asked the radwaste operator for the written procedures by which he operated the facility and was given a book of procedures.
The book of procedures included S.10.4.1.8, Revision 0, " Condensate Phase Separator Decant",
dated January 24,1973; and S.10.4.1.C. Revision 0 " Processing Conden-sate Phase Separator through the Centrifuge", dated January 24, 1973.
Upon review of the licensees master procedures kept in the administra-tion building the inspector found that S.10.4.1.B, Revision 1, "Conden-sate Phase Separator Decant", dated April 11, 1979; and S.10.4.1.C.
Revision 1, " Processing Condensate Phase Separator through the centri-fuge", dated April 18, 1979 were the current revisions in effect.
10 CFR 50, Appendix B, Criterion VI states in part " Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto... these measures shall assure that documents... are distributed to and used at the location where the activity is performed.
The licensees NRC accepted Quality Assurance Plan, Volume III, Section 2, paragraph 6.1 states in part "... documents, including changes... are distributed to and used at the location where the prescribed activity is perfonned." The inspector noted that failure to distribute to and use a current revision of procedures S.10.4.1.B and S.10.4.1.C at the radwaste area represented noncompliance with the 10 CFR 50 Appendix B and Quality Assurance Plan requirements (50-277/79-27-01; 50-278/79-30-01).
The inspector noted that these procedures had check off lists which were required to be completed in the initial step of the procedure and asked to see several of the most recently completed checklists.
The operator stated that the checklist were not routinely completed (i.e.
every time the procedure was performed) but were completed only after repair or maintenance of the involved equipment. The inspector noted that the procedure made no allowance to exempt the checklist requirement for routine processing and that failure to complete the checklist represented noncompliance with procedures developed pursuant to techni-cal specification 6.8 (50-277/79-27-02; 50-278/79-30-02).
The inspector also noted that the current revisions of several procedures were dated as early as 1973 and they had not been reviewed since.
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Packaae Compliance On October 30, 1979 as the inspectors arrived on site a low-level waste shipment was leaving.
Independent measurements were made of radiation levels and the results compared with the licensee's recorded survey result.
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On November 1, 1979 the inspectors examined a 55 gal. drum as it was filled with dewatered resin from the centrifuge.
No free standing water was observed and the resin appeared to have a low moisture content (slightly moist).
Neither the inspector nor the licensee had a method available for determining if water would collect in the bottom of the drum.
The inspectors also observed stored drums of compacted waste and contaminated protective clothing.
No items of noncompliance were identified.
9.
Exit Interview The inspector met with licensee management representatives (denoted in paragraph 1) at the conclusion of the inspection on November 1, 1979.
The inspector summarized the purpose and scope of the inspection and the findings.
Licensee management representatives made the following statements:
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current procedures would be at the radwaste panel that day
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dewatered resin would be sampled to determine if water would collect at the bottom of a sample
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a computer search would be made to identify proceudres as old as five years, these procedures would receive expedited review.