IR 05000277/1993013

Insp Repts 50-277/93-13 & 50-278/93-13 on 930617 & 21-23.No Radiological Safety Concerns or Violations Noted.Major Areas Inspected:Qa Audits & Surveillances,Changes in Radwaste Organization & Training & Qualifications of Personnel

ML20046B278
Person / Time
Site:	Peach Bottom
Issue date:	07/26/1993
From:	Eckert L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20046B267	List: IR 05000277/1993013
References
50-277-93-13, 50-278-93-13, NUDOCS 9308040017
Download: ML20046B278 (13)

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U. S. NUCLEAR REGULATORY COhmilSSION l

REGION I

Report Nos.

50-277/93-13, 50-278/93-13

Docket Nos.

50-277, 50-278

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License Nos.

DPR-44, DPR-56

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Licensee:

Philadelphia Electric Company Nuclear Group Headquarters Correspondence Control Desk P. O. Box 195 Wayne, Pennsylvania 19087-0195 l

Facility Name:

Peach Bottom Atomic Power Station

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Inspection Period:

June 17 and June 21-23,1993

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7hi!73 f

Inspectors:

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L. Eckett, Radiation Specialist Date i

Facilities Radiation Protection Section

Approved By:

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7-2fe ~ 9.3

W. Pasciak, Chief Date

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Facilities Radiation Protection Section Areas Inspected: Quality assumnce audits and surveillances; changes in the radwaste organization; changes in the radiological controls organization; training and qualifications of '

l personnel; implementation of the solid radwaste program; review of radioactive material

shipping records; review of interim radwaste storage; scaling factor analysis; and contamination control.

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Results The audit program was wellimplemented. Radwaste and Radiological Controls staffing was sufficient to implement responsibilities. The solid radwaste program and

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transportation progams were well implemented. The training program and scaling factor development programs were adequate. Contamination control was good and helped the Dry

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Active Waste minimization program to be a success. No radiological safety concerns or violations of regulatory requirements were identified.

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DETAILS i

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~l 1.0 Personnel Contacted l

1.1 Station Personnel l

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• S. Baker, Manager Radwaste

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• F. Crosse, Manager Radwaste Services j

• D. DiCello, Manager Radiological Engineering i

• R. Farrell, Manager Support Health Physics

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• D. Foss, Regulatory Engineer

• B. Knieriem, Site Representative, Delmarva Power

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• S. Lee, Engineer, Nuclear Quality Assumnce (NQA)

• S. McCartney, Services Training

" G. McCarty, Manager, Services Training l

• R. Moore, Manager Radiation Protection l

• R. Smith, Regulatory Engineer l

• B. Wargo, NQA

i Other licensee personnel were contacted during the inspection.

1.2 NRC Personnel

• J. Noggle, Senior Radiation Specialist t

1.3 Commonwealth of Pennsylvania Bureau of Radiation Protection Personnel f

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• S. Miangi, Nuclear Engineer

• Denotes attendance at the exit meeting.

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2.0 Audits and Appraisals I

t Licensee audit A0167275, "Radwaste Shipping and Handling, and Process Control Program",

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7/27/92, was reviewed. As a msult of the audit, three Corrective Action Requests (CARS),

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two deviations, and four recommendations for improvement were identified. The audit report noted that neither the CARS nor the deviations wem indicative of programmatic

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breakdown. One CAR pertained to illegible radioactive material stickers (denoting container

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contents) which was later addmssed by maintaining a listing of container contents both at the i

Health Physics Control Point and Radwaste Branch office. One of the deviations noted by j

the audit team concerned I&E Bulletin 79-19 training for the resin dewatering technician.

l The auditors noted that training had not been provided commensurate with that individual's j

responsibilities. The other deviation concerned a departure from the Low Level Waste i

Storage Facility (LLWSF) access control process in that some personnel signed in on a

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security log rather than the radwaste procedure log. This discrepancy was immediately

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corrected and all individuals involved were found to have current LLWSF access privileges.

The inspectors suggested that inclusion of a radwaste technical expert might help to enhance the quality of future audits. The audit was thorough and where possible, it was performance based.

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The inspectors reviewed licensee audits of vendor supplied services, pmgrams, or facilities.

The following audits were reviewed.

• VA-A-646319, Quadrex Recycle Center, 10/23/92

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This audit was performed by licensee Quality Assurance staff. This audit identified 7

Vendor Cormctive Action Requests (VCRs) and three Recommendations (RECS).

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VA-A-159146, Interstate Nuclear Services (INS),1/16/92

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This audit was perfonned by licensee Quality Assumnce staff. This audit identified 6

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VCRs.

• VA-A-646322, Scientific Ecology Gruup, Incorporated, 10/24/92

This audit was performed by licensee Quality Assurance staff. This audit identified 6 VCRs and 4 RECS.

The lack of licensee oversight (audit) concerning spent fuel pool clean-up (a non-safety related service) was considered an audit program weakness. The licensee was able to pmduce two audits of WasteChem Corporation which had been conducted by Duquesne Light i

Company and Florida Power and Light. Waste Management Group (WMG) performed the

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component characterizations (scaling factor analysis) done during the spent fuel pool clean-up, and no audit had been performed for this service.

Some quality verification responsibilities concerning radioactive material shipments wem moved to the Radwaste Branch. The site Quality Verification (QV) group informed the inspectors of their intent to continue to conduct surveillances on class B and C radioactive waste shipments.

In summary, the licensee audit and appraisal program was considered good.

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3.0 Radwaste Re-Organization / Changes to the Radwaste Program On April 10,1993, a new individual has taken the position of Radwaste Branch Manager.

This individual had served on nuclear propulsioned ships in the U.S. Navy, spent nine years with Bechtel Corporation, spent six-and-a-half years in Quality Assurance within PECo, and from Jan 1992 until April 10,1993 had served PECo as a Quality Verification Supervisor.

I At the time of the inspection, the licensee was developing a more definitive guideline to control the A-30 program (the licensee's housekeeping program). The Radwaste Branch

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i Manager was also evaluating whether changes to the hazardous materials program were -

needed.

The Radwaste Branch had four direct reports, from the Radwaste Technical Foppon

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Supervisor, Radwaste Shipping Supervisor, and two Decontamination Supervisors. The l

Radwaste Technical Support Supervisor and Radwaste Shipping Supervisor positions were i

elevated to management level positions.

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The previous Radwaste Branch Manager was moved to the Radwaste Technical Suppon Supervisor position. Two new individuals were assigned to the Decontamination Supervisor

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positions. The Radwaste Branch Manager informed the inspectors that two additional i

Shipping Engineers were to be assigned by the end of September 1993. The Radwaste Field

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Supervisor position was eliminated and the responsibilities were moved to the Radwaste Shipping Supervisor.

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Twelve technician level positions wem eliminated in the decontamination suppon group. At I

the time of the inspection, the impact of this change was not evident as plant decontamination

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was not a high priority activity as both units were in operation. The Radwaste Branch Manager informed the inspectors that he was carefully evaluating the responsibilities assigned

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to the Radwaste Branch and how the loss of 12 technicians would affect the Radwaste Branch's ability to meet their assigned responsibilities. Movement of responsibilities to other

site organizations was under evaluation.

In conclusion, the Nuclear Effectiveness and Efficiency Design Study (hT.EDS)

reorganization has increased the amount of technical expenise within the Radwaste Branch.

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Plant housekeeping and outage recovery effons will be evaluated in future inspections.

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4.0 Health Physics (IIP) Re-Organization Since the last routine inspection in this program area, a new individual took the position of Radiation Protection Manager (RPM). Per Technical Specification (TS) 6.3.1, the RPM is required to meet or exceed the qualifications of Regulatory Guide 1.8, Revision 1,9/1975.

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The licensee's mview of the RPM's qualifications noted that this individual served in Nuclear Quality Assurance (NQA) from December 12,1983 until November 16,1992 and had spent about 75% of the time in activities directly related to the radiation protection field. It was also noted that the RPM had served as the Health Physics Training Supervisor from November 16,1991 until January 25,1993. The licensee also noted that this individual's experience as a Health Physics Technician (HPT) was invaluable in helping them pedorm

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their NQA and Training roles. The inspectors concluded that this individual met the licensee's TS qualification requirements.

The organization was headed by the RPM. The RPM had eight direct repons, from the Radiological Engineering Manager, the HP Suppon Manager and six Team Supervisors (see i

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Attachment 1) and one administrative assistant. There have been considerable changes in

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personnel within the radiological controls organization conducted under the NEEDS

Reorganization. The Radiological Engineering Manager and HP Support Manager positions j

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were upgraded to Manager level positions. NEEDS changes added two individuals cenified j

by the American Board of Health Physics to the station staff.

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The six Team Supervisors were assigned specific routine job coverage activities such as fuel f

floor coverage, resin de-watering activities, and radioactive materials shipping (see l

Attachment 1).

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l The Radiological Engineering Manager had six direct reports and one administrative assistant

(see Attachment 2). The six Radiological Engineers were tasked with the responsibility of

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developing ALARA plans in assigned plant areas. Each Radiological Engineer was also (

assigned programmatic responsibilities which included the exposure goals program, the hot

. r spot reduction program, the cobalt reduction program, the ALARA suggestion program, the

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chemical decontamination program, and the Radiation Work Permit program.

One of the major impacts from the NEEDS Reorganization on the radiological controls

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organization was the removal of the ALARA Technical Assistant positions. These i

individuals were replaced with degreed health physics " professionals".

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The HP Suppon Manager was supponed by an Instmment Physicist, a Respiratory Physicist, a Dosimetry Physicist and an administrative assistant. Two other individuals were task.ed i

with procedural development and special projects (see Attachment 3). The Instmmentation

Physicist was assigned one HPT and the Dosimetry Physicist was assigned 4 technicians.

A number of licensee personnel improvements have occurred since 1992. Industry

I cooperative committees, trips to other nuclear stations, seminars, and licensee staff have panicipated in additional trammg.

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In conclusion, the NEEDS reorganization has increased the amourt of technical Health

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Physics expenise at the station. However, several individuals were serving in new j

capacities. Progress in this area will be monitored in future inspections.

5.0 Training and Qualifications of Personnel i

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To determine if licensee commitments made in response to I&E Bulletin 79-19, " Packaging l

i of Low-level Radioactive Waste for Tran port and Burial", had been met, the inspectors j

l conducted interviews with training depanment and radwaste depanment personnel, reviewed

the licensce's iesponse to I&E Bulletin 79-19, several peninent lesson Plans (LPs), and j

selected training records.

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i 5.1 Provision of Training

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No in depth training had been provided to some of the shipping engineers since 1988. The licensee provided training to the shipping engineers annually using lesson plan RWB-0010,

"Radwaste Shipping, Handling, & Minimization." Licensee representatives stated that lesson plan RWB-0010 takes about six hours to complete. At the NRC exit meeting, licensee representatives stated that, in their opinion, their training program was consistent with their

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response to I&B Bulletin 79-19.

i In summary, a geneml overview of DOT, NRC and Burial Site requirements and the

I operating procedures which enforce these requimments was provided to shipping engineers.

Other licensees provide a similar curriculum in approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> biennially. The six

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hour course provided by this licensee was considered a pingrammatic weakness and will be I

myiewed in future inspections.

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5.2 Training Conduct i

The responsibility of conducting radioactive waste and transportation was assigned to a single individual. Since the last inspection in this pmgram area, a new individual has taken the radwaste/ transportation training position. This individual has attended a vendor supplied

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(CNSI) radwaste and transportation " train the trainer" course. The inspectors noted that this l

individual has had little prior experience in radwaste and transportation (previously a HPT).

The Manager, Services Training provided the inspectors with the development plan for this

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individual. The inspectors found the plan appropriate and suggested that efforts be made to

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provide a rotational detail to the Radwaste Branch in order to enhance the trainer's radwaste processing and radwaste transportation knowledge base.

The inspectors reviewed the Lesson Plans (LPs) currently in use and found them adequate.

The following LPs were reviewed.

i RWB0010, " Shipment and Receipt of Radioactive Materials," 7/13/92, Revision 4 i

e RWB0020, " Radioactive Material Shipment and Handling (Supervisory)," 11/29/90,

Pevision 1

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RWB0030, " Shipment and Handling of Radioactive Materials for Technicians,"

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6/5/92, Revision 2 RWB0040, " Shipment and Handling of Radioactive Materials for HP Technicians,"

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4/27/92, Revision 2

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Four levels of training have evolved in the areas of transportation and radwaste based on worker experience / status. LP RWB0010 was provided to Supervisors, Quality Assurance,

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Shipping Engineers and Resin Dewatering Technicians on an annual basis. This LP took about six hours to complete. LP RWB0030 took about four hours to complete and was intended for radwast', technicians. LP RWB0040 took about two hours to complete and was intended for HPTs. In practice, this LP was typically challenged for course exemption.

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Basic radwaste and transportati a training was provided as part of General Employee Training.

The inspectors noted that RWB0010 did not cover Revision 1 of the NRC Branch Technical Position (BTP) on Final Waste Classification and Waste. This BTP deals mainly with

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solidification of radioactive waste. At the time of the inspection, the licensee was not processing radioactive vmste through a solidification pmcess. The licensee agreed to

evaluate the necessity of initiating a lesson plan revision to address this revised BTP.

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5.3 Training Program Summarv

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This program area was assessed as being adequately implemented.

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6.0 Implementation of the Radwaste Program 6.1 Descriptica

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As described in the Updated Final Safety Analysis Report (UFSAR), wet solid radwastes from the processing of sp at demineralizer resins (bead and powdered) and spent filter media fmm the equipment and floor drain systems, and from the three (reactor, fuel pool, and condensate) water clean-up systems. These wastes are in the form of spent demineralizer i

resins and filter sludge water slurry which are collected in backwash receiving tanks (2 condensate and 2 clean-up back wash tanks) or in the waste sludge tank. The slurry collected in a backwash receiving tank is pumped on a batch basis to a corresponding phase

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separator. From either the phase separators or the waste sludge tank, the waste is pumped to

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a High Integrity Container (HIC) where it is dewatered and prepared for storage or shipment.

The inspectors noted that the process description contained in the UFSAR concerning the dewatering of wet solid radwastes was not consistent with the current practice of dewatering in a liner rather than by using centrifuges and should be corrected by the licensee.

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As described in the UFSAR, there are four basic liquid collection subsystems and an environmental discharge subsystem comprising the liquid radwaste system. The collection subsystems included the equipment drain subsystem for low conductivity wastes (high purity water), the floor drain subsystem for higher conductivity wastes, the chemical drain subsystem, and the laundry subsystem for cleaning agent wastes.

No Dry Active Waste (DAW) compacting was currently being done on-site. The licensee utilized the services of INS for laundry, Quadrex for metals, and SEG for other DAW.

The following procedure was reviewed.

RW-C-100, " Solid Radwaste System Process Control Program," Revision 0,12/28/92 e

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No pmcedural inadequacies were noted.

6.2 Licensee initiatives

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One notable improvement was underway at the time of the inspection. Tids radwaste/

transportation computer code has been reviewed by the NRC and a topical report has been issued in validation of its method. The licensee had purchased the RADMAN computer code. At the time of the inspection, the Shipping, Engineers had been trained to use this i

code. Implementation awaited procedural development.

6.3 Scaline Factors

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To determine if 10 CFR 61.55(a)(8), " Determination of Concentmtions in Wastes," had been met, the inspectors conducted interviews, reviewed procedures, and reviewed relevant licensee documentation in this area.

Licensee procedure RW-C-100 delineated some requirements concerning the development of scaling factors. That procedure directed a minimum sampling frequency of once per year for each waste stream. The procedure also dimcted quarterly tests (as a minimum) to verify scaling factors.

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A change was made to utilize the ser" ices of Teledyne to perform sample analysis. The

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licensee then used the data from Teledyne to develop their scaling factors. The scaling factors which had been developed and were in use at the time of the inspection included RWCU resin, RW resin (fuel pool, radwaste, and condensate resins), DAW (samples taken

once every two months), oil, Unit 2 fuel pool cmd, and Unit 3 fue1 pool crud. A scaling factor used for control rod drive filters was developed through smear analysis of same.

Sampling / scaling factor determinations were based on a collection of waste sludge tank batches throughout the year, which, on the average, should provide a relatively good

approximation of the three waste stream mixtures. However, for any one batch of resins, the waste stru.n mixture could represent quite different ratios. Also, the three individual contributing waste streams had not been sampled sepamtely to enable proportional weighting for each resin liner contents. This was considered a minor program weakness.

• Changing condenser tubing, spent fuel clean-up, removal of leaking fuel pins, and control rod blade cut-ups are considered to be activities that can affect the radioisotopic content of condensate and fuel pool spent resins. Diluted mixtures of these resins did not facilitate

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refined analysis of these waste streams. For 1992, fuel pool wastes represented about.5%

of this wastestream, radwaste 47%, and condensate 52.5 %.

The licensee agreed to evaluate this matter. The licensee's evaluation will be reviewed in a

future inspection.

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No discrepancies were noted in statistical methodologies used in the development of scaling

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factors.

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6.4 Radwaste Volume Reduction / Decontamination Effolts

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The 1993 radwaste genention goal was set at 575 cubic meters of low-level solid waste. At the time of the inspection,199 cubic meters had been generated in 1993. A downward trend in the volume of radioactive waste sent for burial has been noted over the past few years.

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The burial volume of mdioactive waste during 1992 was 17,501 cubic feet. In 1991, it was i

30,598 cubic feet; in 1990, 28,557 cubic feet; and in 1989,31,578 cubic feet.

A major effort was underway to provide a coating of paint on floor surfaces throughout both l

units. This helps to make decont unination easier. At the time of the inspection, this project

was 68% complete.

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The licensee had established a contaminated area goal of 10% of those areas practical to decontaminate (non-excluded). At the time of the inspection,6% of the non-excluded areas in Unit 2 and common areas were contaminated and 7% of the non-excluded areas in Unit 3

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were contaminated.

6.5 Iow Level Waste (LLW) Facility i

i The inspectors toured the licensee's on-site LLW storage facility. The following tables

provide the change in storage capacity of the LLW facility after facility modification. At the

time of the inspection, the facility was undergoing modifications to accept resin liners.

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Original Design Capacity Number of Containers /Divms/nICs Description 10,800 7.5 cubic foot drums of high radiation material l

210 100 cubic f(xn boxes of high radiation material

850 100 cubic foot boxes of <50 mrem' hour material l

Total Seorage Capacity 187,000 cubic feet

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i Post Cell Modification Capacity

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Number of Containm/DrumsMICs Description 448 202.1 cubic foot HICs or liners of high radiation material l

720 7.5 cubic foot drums of high radiation material 210 100 cubic foot boxes of high radiation material

850 100 cubic foot boxes of <50 mrem / hour material Total Storage Capacity 201,941 cubic feet

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6.6 Innlementation of the Radwaste Procram Summarv

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This program area was assessed as being well implemented.

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7.0 Shipping of low-level wastes for disposal, and transportation

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At the time of the inspection, generators in the Commonwealth of Pennsylvania had radwaste burial privileges. The following shipment records were selected and reviewed.

Identirication No.

Activity Description dot Type 28-93 25.9 Ci Fuel channels and cold LPRM* ends A

L408-93 24.6 mci 22 Laundry bags LSA RMS411-93 3.12 mci underwater filter vacuuming system LSA RMS-012-93 4.86 L2 mci 15 gallon drum of condenaste resin LQ*

RMS424-93 13.2 mci I seavan of DAW LSA

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RMS436-93 7.88 L2 mci 18 55 gauon drums of oil,7 drums of aludge LSA 36-93 13.5 Ci dewatered resins B

34-93 3.13 L2 m i 3 5 gallon buckets to Teledyne LQ e

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8-93 10.9 Ci dewatered resins A

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RMS437-93 18.3 mci DAW LSA

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4-93 91.7 Ci dewetered resins A

CLIRM low power range morutor f

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These records were found complete. The licensee maintained copies of the consignee's

licenses as required. The inspector verified that the licensee was a registered user of the i

I casks used for the shipments noted above. No discrepancies were noted.

The inspectors observed activities associated with radioactive material shipment RMS-037-93.

l No discrepancies were noted.

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8.0 Exit Meeting

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The inspectors met with licensee representatives at the end of the inspection, on June 11, 1993. The inspectors reviewed the purpose and scope of the inspection and discussed the

findings. The licensee acknowledged the findings.

Licensee representatives stated that, in their opinion, their training progmm was consistent I

with their response to I&E Bulletin 79-19.

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R. M. Moore e

Mgr., Rad. Prot.

"T" Miller Secreta!/ Ill D. C. Dicello Mgr., Red Eng'g R. P. Farrell Mgr., H.P. Support l

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N E. D. Preston H. N. Trimble G. 4. SA S. B. Kohlbus N. Weissenrieder W. A. Downey

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"A" Team Supv.

"B" Team Supv.

"C Tes:" 4 v.

"D" Team Supv.

"E" Team Supv.

"F" Team Supv.

g F. P. Kovacs h

S. M. Smith D. M. Birmingham T

J neen L. A. Boddy

• J. K. Blouse R. E. Brown E. K. Tucker J. C. Crabtree W. Posey L. C. Hitdebrard D. T. Striebit D. A. Canpbell W. S. Tome W. C. Dulin D. C. Robinson D. J. Lowman L. Hewell T. A. Fleischmann J. R. Poteet L. E. Hostetter R. L. Workinger T. M. Mcdonald S. A. Lilley L. M. Hildebrecht D. Stein ARC J. T. Schwarz E. E. Workinger J. J. Nelson, Jr.

D. Duer D. E. Shank M. Eckenrode ARC K. L. Williams G. Faden J. L. Zellers C. Hoffmaster J. Moyer P. Szaro ARC T. Albright M. Silvis ARC P. A. Scarborough M. Blasiak ARC J. Dunlap ARC Cat /Bechtel Mods:

D. Ferguson ARC J. Wardlaw ARC R. Smidga ARC Y Shift /FF:

Mod 1106B:

D. Kern R/W Painters:

• Fuel Floor:

T. Kirkpatrick G. Sperbeck BNS (Fri-Tues)

J. Purcell

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Inst. Cage:

F. Volz T. Thorsen ARC 6/21 T. J. Cook BNS Cat /Bechtel Mods:

(Wed-Sun)

(Wed-Sun)

R. D. Nixon J. Oreo ARC (2p-10:30p)

6. Smith BNS Mod 11068:

M. Sechrist Hot Shop

. Scaffold Housekeeping STs/RTs Shipping Dewatering / Resp Valve group Fitters Rotating Equip.

I&C Fuel Floor Decon

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RADIOIDGICAL ENGINEERING - NON-OUTAGE ORGANIZATION Dave Dicello Manager, Rad Engineering Cindy Thompson Typing

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File setup & Maint.

Mtg. Arrangements Timesbeets Training Scheduling RWP Closeout & Archieving Survey Filing Travel Supplies Graphs

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Bruce Miller Dick Sware Dan Droddy Joe Volz Matt llorvatinovic Debbie O'Connell H

w Shielding Mods TIPS Fuel Floor RWCU Planning SARC TB RX-135'

Outside RCAs RX-165'

Rx-195'

Event Invest.

RW RX-ll6' &

Station & ilP Fuel Trending RX-214'

Robot use &

• Hot Spots below (Torus Dose PIs RX-180'

Fan Rms.

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& RHR)

Recombiner Bldg

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• RWP Program Core Spray PIMS Testing Applied llPCI Applied Supervisor RCIC Supervisor

• A1 ARA Sugg Sump Room

• Cobalt (RX Bldg.)

Reduction

• Dose Goals

• Programmatic Responsibility

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