IR 05000277/1986021

Insp Repts 50-277/86-21 & 50-278/86-22 on 861020-24. Violations Noted:Failure to Identify & Classify Radionuclides in Dry Active Waste Shipment & in Solidified Filter Shipment,Respectively

ML20214K968
Person / Time
Site:	Peach Bottom
Issue date:	11/18/1986
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214K919	List: IR 05000277/1986021 ML20214K918 ML20214K926
References
50-277-86-21, 50-278-86-22, NUDOCS 8612020530
Download: ML20214K968 (11)

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No /86-21 and 50-278/86-22 '

Docket Nos. 50-277 and 50-278 License No DPR-44 and DPR-56 Category C Licensee: Philadelphia Electric Company -

2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: October 20-24, 1986 Inspector: . . L w //!/8 96 H. J.*Bice e, Radiation Specialist date f

Approved by:

,0 A I

- _)c R. J. jPas'c'iak, Chief, Ef fluents Radiation

". is idate A

Protection Section Inspection Summary: Inspection on October 20-24, 1986 (Combined Report No /86-21; 50-278/86-22)

Areas Inspected: Routine, unannounced inspection of the licensee's transporta-tion activities (i.e. radioactive waste preparation, packaging and shipping program) including: previously identified items, management controls, quality assurance / quality control and implementation of the program. Mr. David Ney of the Pennsylvaaia Department of Environmental Resources accompanied the inspec-tor on October 20-23, 198 Results: Apparent violations of 10 CFR 20.311(b) and (c) and 10 CFR 71.5(a)

(1)(vi) relating to a dry active waste shipment (Detail 8.1) and 10 CFR 2 (c) and (d)(1) for t solidified filter shipment (Detail 8.3) were note Rh20gggteebbg;7 G

.

.

DETAILS Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewed:

1.1 Licensee Personnel

• Mr. D. Smith, Superintendent-Operations (Acting Station Manager)

• Mr. J. Cotton, Superintendent-Plant Services Mr. F. Crosse, Radwaste Physicist (Radioactive Material Coordinator)

Mr. A. Hilsmeir, Senior Haalth Physicist (Radiation Protection Manager)

• Mr. W. Lorenz, Senior Health Physicist (Corporate)

• Mr. G. McCarty, Support Health Physicist

• Mr. J. McElwain, Supervisor, Quality Control Mr. W. Stewart, Quality Control Inspector

• Mr. R. Sutton, Engineering & Research Quality Assurance Mr. D. Wheeler, Reactor Engineer

• Mr. T. Wilson, Station Quality Assurance Other licensee personnel were contacted or interviewed during the course of this inspectio .2 Contractor Personnel Mr. M. Dragoo, Manager, Fuel Pool Project, Chem-Nuclear Service Other contractor personnel were contacted or interivewed during the course of this inspectio .3 NRC Personnel Mr. T. Johnson, Senior Resident Inspector

• Dr. W. Pasciak, Chief, Effluents Radiation Protection Section

• Mr. H. Williams, Resident Inspector

• Attended the exit interview on October 24, 198 . Scope of the Inspection This routine inspection reviewed the licensee's solid radioactive waste (radwaste) preparation, packaging and shipping program as implemented by the licensee from August 1, 1985 through October 23, 1986. During the period, the licensee made approximately 25 shipments per month. A sample of 20 shipments providing examples of shipments of dry active waste (DAW),

dewatered resins, solidified radwaste materials and reactor components was selected and reviewed relative to the licensee's Technical Specifications, radwaste generator requirements in 10 CFR 20.311 and 10 CFR 61.55-56 and radioactive materials shipper requirements in 10 CFR 71 and 49 CFR 170-189. The licensee's actions regarding previously identified items were also reviewe .

.

3 Previously Identified Items 3.1 (Closed) Followup Item (50-277/85-31-02; 50-278/85-28-02) Revise FH-48C to include acceptance criteria and eliminate contamination exter-nal to FSV-1 cask. The licensee revised Fuel Handling (FH) Procedure 48C, " Handling of the FSV-1 Casks," to include acceptance criteria for radiation dose rates for collected drainage water and " soap tests" for cask leakage. The licensee also changed the procedure to allow access to the trunnion cup area for contamination surveys following water drainage. This item is close .2 (Closed) Violations (50-277/85-31-03; 50-278/85-28-03; 50-277/85-31-04; 50-278/85-28-04) Failure to correctly list radionuclides and their activities and incorrect waste manifest certification for Ship-ment No. 145-85. Actions described in the licensee's letter (dated October 30,1985) regarding these items were reviewed. The licensee had completed actions as described in the letter and these actions appeared to be adequate to prevent recurrence of inappropriate ship-ping papers for control rod blade shipments. These items are close .3 (Closed) Violation (50-277/85-31-05; 50-278/85-28-05) Contamination on the external surface of the FSV-1 cask greater than 220 dpm/cm2 ,

Actions described in the licensee's letter (dated October 30,1985)

regarding Shipment No. 169-85 were reviewed. Revisions to FH-48C were made by the licensee to remove the FSV-1 cask from the truck following water drainage to allow surveys of the trunnion cup are No problems with external contamination were noted on FSV-1 cask ship-ments subsequent to the change. This item is close .4 (Closed) Violation (50-277/85-39-01; 50-278/85-40-01) Failure to assure easy access to pallet lifting slings for removal of pallets at the waste burial site. Design changes to prevent entanglement of the lifting cables (as described in the licensee's letter dated January 7, 1986) were reviewed and appeared adequate to prevent re-currence of the problems noted in South Carolina Department of Health and Environmental Control (SCDHEC) Report No. 85-10-02 regarding licensee Shipment No. 255-85. This item is close . Organization The licensee's organization was briefly reviewed to determine if clear designations of responsibilities were provided for radwaste processing, packaging and shipping activities. Four groups share responsibility for radweste activities. The Operations group is responsible for the opera-tion of systems and processes which generate, transfer and package low-level radwaste (e.g. dewatered resins). Within the Operations group, the Radwaste Supervisor has direct responsibility for packaging and transport of radwaste for off-site disposa The inspector noted that the Radwaste .

Supervisor's duties had been split between the Radioactive Material Coord-inator and a rotation of acting Radwaste Supervisors since the retirement

_

.

-

of the previous Radwaste Supervisor. Within the Health Physics Group, the Radioactive Material Coordinator (RMC) maintains records of radwaste ship-ments and acts as a technical advisor to the Radwaste Supervisor. The RMC reports to the Support Health Physicist who, in turn, reports to the Sen-for Health Physicist. Special radwaste disposal operations, (e.g. control rod blade disposal and fuel pool cleanup projects) are under the cogni-zance of the Reactor Engineering Grou Independent inspection of packag-ing and shipping activities are the responsibility of Quality Control (QC)

inspectors under the QC Superviso Within the scope of this review, no violations were note However, the responsibilities of the Reactor Engineering group appeared to be ill-defined and the interface between the RMC and Reactor Engineer-ing group regarding classification-of special radwaste shipments, develop-ment of procedures for handling and processing special radwaste shipments and technical management of these activities appeared unclear to the in-dividuals involved. The lack of clear technical management responsibil-ities appeared to contribute to the problems noted in Combined Inspection Report Nos. 50-277/85-31; 50-278/85-28 regarding FSV-1 cask shipments and in this report regarding apparent misclassification of Shipment No. 119-86(Detail 8.3).

5. Procedures The licensee's procedures for preparation, packaging and shipping rad-wastes were reviewed relative to criteria provided in Technical Specifi-cation 6.8, " Procedures," and regulatory requirements in 10 CFR 20.311,10 CFR 71 and 49 CFR 170-189. Routine procedures in the health Physics (HP)

and Systems (S) series and special procedures in the Fuel Handling (FH)

and Special Procedure (SP) series were reviewed to determine if instruct-ions regarding regulatory limits and acceptance criteria were provide The technical bases for identification of radionuclides, quantifications of activities and determination of classification under 10 CFR 61.55 and waste form under 10 CFR 61.56 were reviewed and discussed with members of the Health Physics and Reactor Engineering staff Within the scope of this review, the following item was noted:

Procedures to update the computer database for scaling factors used to quantify activities of hard-to-identify radionuclides in the radwaste streams and obtain additional radwaste samples for gross activity changes in the Reactor Coolant System were not provided. The licensee established a database of scaling factors in 1983 based on generically-derived values (e.g. NUREG/CR-4101). A contractor provided radiochemical analysis of waste samples, radionuclide database updates and correlation (i.e. scal-ing) factor determinations in December 1983, February 1984, May 1984, November 1984 and July 1985. However, the licensee's computer program database for correlations between gamma-emitting isotopes (e.g. Cobalt-60 and Cesium-137) and hard-to-identify isotopes, (e.g. Iron-55, Strontium-90, Nickel-63 and various Transuranics) wasn't systematically updated as

.

I

-

the results of these analyses became available. The licensee's MIDAS Fortran IV program database for correlations was compared to the latest contractor's recommended correlation factors on October 20, 1986:

Radionuclide Waste MIDAS Program (a) Contractor Value(b) Ratio (b)/(a)

Strontium-90 DAW 5.4E-4 (Cs-137) 1.2E-3 (Cs-137) 2 Iron-55 DAW 8.2E-2 (Co-60 ) (C0-60 ) 280 Nickel-63 DAW 1.1E-1 (Co-60 ) 5.7E-2 (Co-60 ) Plutonium-238 Primary 5.6E-4 (Ce-144) 7E-3(Ce-144) 1 Resin

. Plutonium-241 Primary 4.14E-4 (Ce-144) 7E-1 (Ce-144) 1690 Resin Americium-241 Primary 2.56E-4 (Ce-144) 3E-3 (Ce-144) 1 Resin Curium-242 Primary 4.07E-3 (Ce-144) 3E-2 (Ce-144) Resin Carbon-14 Primary 4.4E-4 (Co-60 ) 4E-3 (Co-60 ) 9 Resin In 1984, Unit 3 experienced fuel failures (resulting from presumed crud induced localized corrosion or CILC) which altered the offgas and reactor coolant system activity (see Combined Inspection Report Nos. 50-277/84-35; 50-278/84-29). Although radwaste samples were taken and analysed by the licensee's contractor, the licensee didn't update the databas NRC IE Information Notice No. 86-20, " Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61," (March 28, 1986) states, in part, that continued use of scaling factors which produce estimates of radionuclide concentrat-ions that differ from the most recent actual measurement of that radio-nuclide by generally more than a factor of 10 may constitute noncompliance with 10 CFR 61.55(a)(8) since the reasonable assurance of correlation standard cannot be me At the exit interview on October 24, 1986, the licensee stated that the computer database would be updated to include the latest scaling factors recommended by the licensee's contractor. The inspector noted that the lack of update to the database contributed to the Iron-55 problems noted with DAW Shipments (Detail 8.1). The inspector stated that the licensee's procedures for updating toe database and the database in use would be re-viewed during subsequent inspections. 50-277/86-21-01; 50-278/86-22-01 l

,

i

\

I

.

-

6 Indoctrination and Training The indoctrination and training of personnel assigned to radwaste shipping activities were reviewed relative to commitments in the licensee's letter (dated September 28,1979) in response to NRC IE Bulletin No. 79-1 Selected training records for annual retraining in 1985 and the associated lesson plan were reviewe Within the scope of this review, the following deviation was noted:

Twenty-one operating personnel failed to attend the 1985 annual radwaste training including 12 auxiliary operators, 3 plant operators, 5 shift su-pervisors and a shift superintendent. Special training sessions were held and the 21 personnel subsequently received training in 1986. The inspec-tor noted that this deviation had been identified as a result of Quality Assurance Audit No. AP 86-02 HPC, (item AP 86-02-04 (NCR)). The inspector also noted that the item met the mitigative tests of 10 CFR 2, Appendix C as a " licensee identified" ite . Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a qual-ity assurance (QA) program for the packaging and shipping of radioactive materials. A Commission-approved QA program which satisfies the applic- '

able criteria of Appendix B to 10 CFR 50 and which is established, main-tained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H. The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radwaste material Specific quality control (QC) requirements to assure compliance with 10 CFR 61.55 waste classification and 10 CFR 61.56 waste form requirements are mandated by 10 CFR 20.311 for waste generators in addition to the gen-eral QC requirements of 10 CFR 50, Appendix B. The implementation of QA/QC activities to the preparation, packaging and shipment of solid rad-waste was reviewe The inspector noted that the site QA/QC organizations were responsible for implementing all applicable QA criteria to the pre-paration, packaging and shipment of radwastes including audits of the pro-gram. Audits of vendor programs, (e.g. shipping containers and solidifi-cation vendors), were the responsibility of the corporate QA organization, (i.e. Engineering and Research Department QA).

7.1 Site QA/QC The site QC organization provides inspections covering radwaste pre-paration, packaging and shipping. Detailed Monitoring Checklists have been developed covering these activities. Mandatory inspection hold points in routine and special procedures related to preparation, packaging and shipping require witnessing or inspection by QC per-sonnel prior to continuation of the procedures. Review of records

.. .- - _-._ - .- _ _ - - - --

to

'

'

related to shipments of DAW, dewatered resins, solidified filters and reactor components showed that designated QC activities .had been complete The site QA organization schedules, performs, reports and close; audits related to radwaste preparation, packaging and shippin Audit No. AP 86-02 HpC, "PBAPS Radioactive Waste / Material Storage, Handling and Shipping," (January 1 - February 4,1986) was reviewe ,

'

The audit was conducted by a trained QA auditor and included a review of the licensee's radwaste administrative controls and verification

'

I of the implementation of those controls. However, the audit was very limited in its review of 10 CFR 61 compliance under 10 CFR 20.31 The audit did not examine the database for inclusion of updated scal-

! ing factors and failed to note the problem with Iron-55 in DAW ship-ments. Although the auditor was technically knowledgeable in the

'

radwaste area, the licensee failed to provide additional technical expertise to assist the auditor in completing the broad scope of the audit. No other audits were conducted of this area. The inspector noted that licensee management had reviewed the audit. At the exit interview on October 24, 1986, the inspector discussed the scope of

'

the audit, the need for close examination of waste generator require-t ments under 10 CFR 20.311 and the lack of technical support provided to the QA audito .2 Corporate QA Audits of vendor programs by the Engineering and Research Department QA organization were briefly reviewed. On December 13-14, 1984, the licensee reviewed the QA program for shipping containers leased from i Westinghouse Hittman Nuclear, Inc. The audit reviewed equipment and 1 services provided by the vendor at the vendor's Columbia, Maryland l office. The inspector noted that four other vendors, (i.e. Chem-

'

Nuclear Services, Inc. Bartlett Nuclear Services, Hydro Nuclear Inc.

'

and Science Applications Inc.) had also provided equipment or serv-l ices in support of the licensee's radwaste preparation, packaging and

!

shipping program. However, during the period 1984-86, site audits of

< these vendors had not been completed by the license . Implementation

The implementation of the Itcensee's program for preparation, packaging

, and shipping radwastes was reviewed relative to criteria in 10 CFR 20.311 i 10 CFR 71, 49 CFR 172-173 and the licensee's Technical Specifications and i procedure Each shipment examined was reviewed to determine the adequacy l of:

-

classification under 10 CFR 20.311 and 10 CFR 61.55;

-

waste form under 10 CFR 20.311 and 10 CFR 61.56;

-

radiation and contamination measurements; I -

shipping paper and waste manifest documentation;

,

l i

- --- -...-.---.--- - - - ._--- --,- - . - - . - - - - - -

y

.

-

package marking and labeling; >

-

loading and storage of packages;

-

vehicle placarding; and

-

notification to state agencies (as applicable under 10 CFR 71.97).

8.1 DAW Shipments On February 28, 1986, the licensee shipped 14 boxes of dry active waste as Shipment No. 45-86 to Richland, Washington. Review of the shipping records for that shipment indicated the following viola-tions:

-

10 CFR 20.311(b) requires, in part, that the manifest accompany-ing radwaste shipments indicate as completely as practicable the radionuclide identity and quantity and the total radioactivity of the shipment Contrary to this requirement, the licensee failed to identify the radionuclide Iron-55 and its activity on the radwaste ship-ping manifest for Shipment No. 45-86. The licensee's vendor analysis of dry active waste within the plant identified the presence of Iron-55 and provided a scaling factor of 2.3 rela-tive to Cobalt-60 activit The presence of Cobalt-60 was identified by the licensee in 13 of the 14 metal boxes of dry active waste shipped. The shipping manifest failed to list Iron-55 as a constituent and include this activity in each of the boxes listed below. The inspector calculated the activities involved for each box using the vendor-derived scaling factor of 2.3 relative to Cobalt-60 activity:

Box N Co-60 (millicuries) Calculated Iron-55 (millicuries)

B014-86 1.15 2.64 B018-86 0.44 1.01 B062-86 1.92 4.42 B059-86 1.37 3.15 B057-86 5.90 13.57 B074-86 23.47 53.98 B073-86 17.54 40.34 B060-86 1.63 3.75 B061-86 10.52 24.20 B064-86 4.78 10.99 B065-86 3.95 9.08 B075-86 8.17 18.79 B076-86 7.42 17.07 Since Iron-55 was not identified and its activity determined for each box in the shipment containing Cobalt-60, the manifest accompanying the shipment contained an incorrect total activity i

_ _ _ - _ , , - . _ . , _ _ _ _ _ - _ _ . , , _ _ , .-._ _ _ , , _ _ _ _ . , , , _ . . , _ . _ _ __ _ _ _ __,_--___,me.#

.

for the shipment. Failure to identify Iron-55, determine its activity in the shipment and include the radionuclide in the total radioactivity of the shipment constitutes an apparent vio-lation of 10 CFR 20.311(b). 50-277/86-21-02; 50-278/86-22-0 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly describe Contrary to this requirement, the licensee certified that Ship-ment No. 45-86 was properly described when the identity of one of the radionuclides was missing and the activity due to that radionuclide was not identified and included in the total activ-ity of the transported material Certification that Shipment No. 45-86 was properly described when it wasn't constitutes an apparent violation of 10 CFR 20.311(c). 50-277/86-21-03; 50-278/86-22-0 CFR 71.5(a)(1)(vi) requires preparation of shipping papers in accordance with 49 CFR 172, Subpart C. 49 CFR 172.203(d)(1)

requires the name of each radionuclide in the shipment and 49 CFR 172.203(d)(iii) requires the activity of each package in the shipment be included in the shipping papers. Contrary to the requirements, the licensee failed to include Iron-55 and the activity resulting from that radionuclide in the shipping papers associated with Shipment No. 45-8 Failure to name Iron-55 and include the activity due to that radionuclide in the shipping papers associated with Shipment No. 45-86 constitutes an appar-ent violation of 10 CFR 71.5(a)(1)(vi). 50-277/86-21-04; 50-278/86-22-0 The inspecter noted that the licensee had omitted Iron-55 on dry act-ive waste shipments (including the one cited above) due to the lic-ensee's failure to update the MIDAS Fortran IV program used to cal-culate activities of hard-to-identify radionuclides. At the exit interview on October 24, 1986, the licensee's representative acknow-ledged the omission of Iron-55 in the waste manifest and shipping papers and provided the following corrective actions:

-

the licensee will review dry active waste shipment records from May 1984 to October 1986 (estimated 100 shipments) and calculate any missing radioisotopes;

-

the licensee will notify the Department of Transportation and the states of Washington and South Carolina and update records associated with shipments affected by the omission of Iron-55; and

-

the licensee will update the Semiannual Radioactive Effluent and Waste Disposal Reports to include activities due to Iron-5 a

'

8.2 Dewatered Resins Six dewatered resin shipments (representing Condensate and Reactor Water Cleanup resins) were reviewed as described above. Within the scope of this review, no violations were note .3 Solidified Filters Licensee Shipments Nos. 119-86 and 145-86 containing filters solid-ified in concrete were reviewed as described above. Within the scope of this review, the following violations were noted:

-

10 CFR 20.311(d)(1) requires, in part, that licensees prepare wastes so that the waste is classified according to 10 CFR 6 . 10 CFR 61.55(a)(3)(ii) requires, in part, that wastes con-taining long-lived radionuclides (listed in Table 1 of that paragraph) exceeding 0.1 times the value in Table 1 be class-ified as Class Contrary to these requirements, licensee's Shipment No. 119-86 contained Carbon-14 in a concentration exceeding 0.1 times its Table 1 value of 8 curies per cubic meter and the licensee class-ified the waste as Class B. On May 15, 1986, the licensee ship-ped approximately 93.37 curies of Unit 2. filters solidified in concrete to Barnwell, South Carolina. The radioactive shipment manifest (No. 1865020671) accompanying the shipment listed the Waste Class as Class B. Review of the activities for the long-lived radionuclides in the shipment indicated that 969 milli-curies of Carbon-14 were present in a waste volume of 0.532 cubic meters. The concentrations of Carbon-14 present in the waste equals 0.969 curies divided by 0.532 cubic meters or 1.82 curies per cubic meter. Table 1 of 10 CFR 61.55 lists a value of 8 curies per cubic meter for Carbon-14 and 80 curies per cubic meter for Carbon-14 in activated metal. Since the ship-ment contained filters, the appropriate Table I limit was 8 curies per cubic mete CFR 61.55(a)(3)(ii) states "If the concentration exceeds 0.1 times the value in Table 1 but does not exceed the value in Table 1, the waste is Class C." Since the Carbon-14 in Shipment No. 119-86 exceeded 0.8 curies per cubic meter (0.1 times the value in Table 1) but did not exceed 8 curies per cubic meter, the waste should have been classified as Class C. The sum of the fractions for the Carbon-14 fraction and the other long-lived radionuclides listed in Table 1 of 10 CFR 61.55 did not exceed 1 (10 CFR 61.55(a)(7) test) which in-dicated that the shipment did not exceed Class C limit Review of records pertaining to the solidification showed that a pro-cess control program had been performed to provide a suitable waste form under 10 CFR 61.5 Failure to classify Shipment N as Class C in accordance with 10 CFR 61.55(a)(3)(fi) con-stitutes an apparent violation of 10 CFR 20.311(d)(1). 50-277/

86-21-05; 50-278/86-22-05

..

s

-

10 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly classif-1ed. Contrary to this requirement, the licensee certified that Shipment No.119-86 was properly classified when the shipment was classified as Class B. Since the shipment was actually Class C, certification that the shipment was properly classified when it wasn't constitutes an apparent violation of 10 CFR 20.311(c). 50-277/86-21-06; 50-278/86-22-06 8.4 Irradiated Reactor Components Shipments of irradiated control rod blades and reactor hardware were reviewed as described above. The inspector noted that the licensee was conducting a cleanup program to remove and send for disposal irradiated items stored in the units' fuel pools under the cognizance of the Reactor Engineering Group. Shipment No. 245-85 containing 4 control rod blades and Shipment No. 200-86 containing reactor hard-ware were reviewed in detail. Within the scope of this review, no violations were note . Exit Interview The inspector met with the licensee representatives (denoted in Detail 1)

at the conclusion of the inspection on October 24, 198 The inspector

. summarized the scope of the inspection and the findings. The inspector discussed the apparent quality assurance problems, (e.g. failure to update the computer database as analyses were completed), and indicated their apparent contribution to the problems note The licensee's representa-tive indicated that licensee management fully intended to correct the problems noted promptly and provided initial corrective actions as des-cribed in this report. The inspector gave the licensee's representative a copy of NRC IE Information Notice No. 86-20. No other written material was provided to the licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.