IR 05000289/1987021

Insp Rept 50-289/87-21 on 871102-06. No Violations or Deviations Noted.Major Areas Inspected:Solid Radwaste Process,Packaging & Shipping Program,Mgt Controls,Qa/Qc, Radiochemistry & Radwaste Generator

ML20237C081
Person / Time
Site:	Three Mile Island
Issue date:	12/10/1987
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237C079	List: IR 05000289/1987021 ML20237C077
References
50-289-87-21, IEB-79-19, IEIN-84-50, IEIN-87-007, IEIN-87-031, IEIN-87-31, IEIN-87-7, NUDOCS 8712210015
Download: ML20237C081 (9)

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V. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.87-211 Docket N i License No. DPR-50 Priority --

Category C Licensee: GPU Nuclear Corporation  ;

P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island - Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: November 2-6, 1987 l Inspectors: itw t w bo. 8, /99 7 H. Bic'etWuse, Radiation Specialist date Approved by: fk -d 6 Oc, /0 /7U W . 7asNaK, Chief date>'

Effluents Radiation Protection Section I l

Inspection Summary: Inspection on November 2-6, 1987 (Report N ~f0-289/87-21) )

I Areas Inspected: Routine, unannounced safety inspection of the licensee's solid radioactive waste (radwaste) processing, preparation, packaging and '

shipping program including previously identified items, management controls, quality assurance / quality control (QA/QC), radiochemistry, radwaste processes, radwaste generator and radioactive materials shipping requirement j Results: No violations or deviations were noted. The licensee was implementing an effective program in the areas examine >I^

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Details 1. Persons Contacted 1.1 Licensee Personnel l

L *J. Boyer, Radwaste Operations, Engineer - TMI-1

• D. Hassler, Licensing Engineer

• J. Hess, Supervisor, Waste Disposal '

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• D. Hosking, Operations Quality Assurance Manager

• C, Incorvati, Quality Assurance Audit Manager - TMI

• B. Mehler, Supervisor, Radwaste Operations - TMI-1

• J. Schmidt, Radiological Engineer - TMI-1

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C. Sitz, Chemist, TMI-1 S. Williams, Radiological Engineer - TMI-1 Other licensee and contractor personnel were also contacted or interviewed during the course of the inspectio .2 Pennsylvania Department of Environmental Resources Personnel

• A. Bhattacharyya, Nuclear Engineer- Bureau of Radiation Protection (BRP)

• R. Janati, Nuclear Engineer, BRP 1.3 NRC Personnel

• R. Conte, Senior Resident Inspector

• D. Johnson, Resident Inspector

• Attended the exit interview on November 6, 198 . Scope of the Inspection This routine safety inspection reviewed the Three Mile Island (TMI) Unit 1 solid radioactive waste (radwaste) processing, preparation, packaging and shipping program (as implemented by the licensee) from May 1986 through October 1987. During that period, TMI Unit 1 made 106 shipments of radioactive material. Radwaste shipments for 1986 totalled 7.65 curies (7,513 cubic feet) and for 1987 (through October) totalled 235.56 curies (7,060 cubic feet). A sample of 9 shipments of solid radwaste from Unit I was selected and reviewed relative to requirements in 10 CFR 20.311, 10 CFR 61.55-56, 10 CFR 71, 49 CFR 170-189, Agreement State License conditions and the licensee's Technical Specifications. In addition, radiochemical parameters in the Unit I reactor coolant system (RCS) were reviewed for potential impact on radwaste stream characterization and previously identified items were reviewe i

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3 Previously Identified Items 3.1 (closed) Follow-up Item (50-289/84-36-01) Control of investigation levels for environmental samples. The licensee revised Procedure:

'No. 9420-SUR-4523.05 to address investigation levels., (i.e. " action levels"). Review of the revision showed the " action levels" to be~

technically adequate. Adherence to the procedure for investigation of levels equalling or exceeding the " action levels" will be reviewed in a subsequent inspection. This item is close .2 (closed) Unresolved (50-289/84-36-02) Review of vendor laboratory procedure The licensee reviewed the vendor laboratory procedures l during technical review of bids received during the contracting-process. The licensee' determined that the procedures were-technically adequate to determine radioactivities of the various radionuclides at environmental levels. Ongoing intra and inter laboratory comparisons of split and spiked samples and quality assurance oversight of vendor activities showed that the procedures were being followed and were producing acceptable radioanalytical results. This item is close .3- (closed) Unresolved (50-289/86-06-03) Quality control of dewatering operations. The licensee monitors.and documents-vendor-supplied dewatering and solidification activities including specific process control parameter verification. Operations Quality: Assurance 4 personnel also monitor each aspect of the process at least once per vendor radwaste dewatering or solidification campaign.- This item is >

close .4 (closed) Violation (50-289/86-19-08) Failure to include assessment of. doses to individuals inside site boundar As described in the licensee'sletter(datedJanuary 27,1987) in response to the NOV, the licensee updated 6 reports to show that no members of the general public were inside the site boundary, requested a Technical Specification amendment to clarify the requirement and thus, completed actions in the letter. This item is close .0 Management Controls 4.1 Organization The organizational relationships and structure of the licensee's management control of solid radwaste processing, preparation, packaging and shipping activities were reviewed relative to descriptions in the Final Safety Analysis Report (FSAR) as updated and technical specification requirements. Oversight of contractor activities (NRC IE Information Notice No. 87-07) was also reviewe _ _ _ - _ _ - . _ _ . -_ - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ - - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ __ _ __

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The Unit 1 Operations Group had responsibilities for processing and packaging compactable dry active waste (DAW), dewatering and i

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solidification of resins and processing of mechanical filter Those responsibilities were carried out by Radwaste Operations under ,

the Unit I supervisor. In essence, this group processes solid radwaste from Unit I to a shipable form. Radiological Engineering personnel assigned to Unit 1 provided calculations needed to support i radionuclides activities, classification under 10 CFR 61.55, gas and heat generation rates and "LSA", Type "A" or "B" determinations under 10 CFR 71. A site-wide shipping group made the actual shipments including preparation of radioactive shipping records and radwaste manifests. Quality Assurance personnel provided receipt inspections of packages, vehicle inspections, monitoring of radwaste preparation, surveillance and inspections of shipping operations and audits of the operation.

Within the scope of this review, no concerns were identifie Although several groups were involved in the processing, preparation, packaging and shipping program, the interfaces were well-defined, responsibilities were understood and the program appeared to be smoothly functionin .2 Procedures i The licensee's procedures for processing, preparation, packaging and shipping solid radwaste materials were reviewed relative to criteria in 10 CFR 20.311,10 CFR 71.5,10 CFR 71.12, Agreement State Burial Site licenses and Unit 1 Technical Specifications. Twelve procedures were reviewed for technical and regulatory adequacy, discussed with the licensee and checked for implementation (as appropriate) for the nine shipments reviewe Within the scope of this review, no violations were noted. The procedures were adequate from both technical and regulatory points of view and had been appropriately implemented for the nine shipments reviewe .3 Indoctrination and Training The licensee's indoctrination and training program (as it related to solid radwaste processing, preparation, packaging and shipping activities at Unit 1), was reviewed relative to commitments in the licensee's response to NRC IE Bulletin No. 79-19. Training provided to fifteen individuals providing selected responsible activities associated with the nine shipments was reviewed with Training personnel, discussed with the individuals trained and training records were briefly reviewed. The inspector noted that the licensee's training programs were fully accredited by the Institute for Nuclear Power Operations (INP0).

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i Within the scope of this review, no deviations from commitments to NRC IE Bulletin No. 79-19 were noted. Biennial retraining of  ;

supervisory personnel was completed as require . Qiality Assurance (OA)/ Quality Control (QC)

Specific quality control requirements are mandated by 10 CFR 20.311 to I assure compliance with 10 CFR 61.55-56. The establishment of a Quality Assurance program for the packaging and transportation of radioactive materials is required by 10 CFR 71, Subpart H. A Commission-approved Quality Assurance program which satisfies the applicable criteria of 10 CFR 50, Appendix B, quality assurance program and which is established, maintained and implemented for transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H. The licensee elected to apply the established 10 CFR 50, Appendix B quality assurance program to packaging and shipping activities. Guidance regarding applicable criteria for a quality assurance program for transport packages was provided in NRC IE Information Notice No. 84-5 Guidance regarding waste classification was provided in the Branch Technical Position on Waste Classification and NRC IE Information Notice No. 86-20. Guidance on waste form was provided in the Branch Technical Position on Waste Form. NRC IE Information Notice No. 87-07 reminded licensees of their responsibilities to ensure process control for vendor-supplied dewatering and solidification services. The application of the licensee's quality assurance / quality control program to the licensee's responsibilities as a solid radwaste generator and shipper at Unit I was reviewed. The inspector noted that the licensee had ,

determined that the activities involved in processing, packaging and '

shipping were "important to safety."

5.1 Waste Generator QC/ Process Control Program l Technical Specification 3.22.3 requires a process control progra The licensee utilized contracted dewatering and solidification services for bead and filter ion exchange resins and evaporator concentrates. Process control procedures for those vendor operations were reviewed to determine verification of proper radwaste form under 10 CFR 61.56 for roe dewatered and solidified resins and concentrates. Both radwaste operations supervisory and quality assurance personnel verified the vendor's provision of suitable waste forms. Calculations for determining waste classification under 10 CFR 61.55 were peer-reviewed within the Radiological Engineering group and checked by shipping personne The calculations were also reviewed on a sampling basis during quality assurance audits. QA Audit Report S-TMI-87-05, "Radwaste Management Program," (conducted March 19-May 11, 1987) was reviewed to determine its inclusion of attributes related to 10 CFR 61.55-56, licensee management review of that audit and resolution of findings and recommendations. The audit included appropriate attributes and had been reviewed by licensee managemen Findings remained open

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i e c: with ongoing program improvements,in training expected to be _

completed by January, 1988. The licensee's QA group was closely j following the finding Within the scope of this review, no violatiotis or concerns were noted. The licensee was implementing an effective QC program under ..

10 CFR 20.311 and Technical Specification 3.22.3 for Unit .2 Radioactive Materials Shipper QC/QA i Under the licensee's Operational; Quality Assurance Plan (0QAP), the licensee had delineated each section of 10 CFR 71, Subpart H and.its corresponding section in the 0QAP. QA Audit Report S-TMI-87-05 reviewed each applicable attribute of the 0QAP from-QC receipt inspections to final shipment QC inspections and monitoring activities. For the nine shipments. reviewed, the inspector verified that the licensee had:

inspected applicable items of each package's Certificate of Compliance (for shipping casks) or purchase specifications (for

" Strong-tight" packages);

inspected and controlled liners and high integrity containers (HICs);

. conducted monitoring and surveillance activities on ongoing preparation, packaging and shipping activities; and implemented the 0QA Within the scope of this review, no violations were noted. The-licensee was implementing a QC/QA program in agreement with guidance provided in NRC IE Information Notice No. 84-50. The thoroughness of Audit No. S-TMI-87-05 was especially noteworthy, Radiochemistry Radiochemical trend data was reviewed for 1986-87 to determine the general adequacy of the licensee's Unit I sampling and vendor analysis program for difficult-to-identify radionuclides. The inspector noted that substantial increases in fission product cctivity in the reactor coolant system (RCS) indicative of fuel failure vere not eviden Similarly, substantial increases in activation product concentrations in the RCS. indicative of resuspension of solids in the system were not evident. The licensee hadn't placed radwaste equipment or processes into service for which no scaling data were available. Chemical decontamination of the primary system had not been undertaken which could generate unusual ion exchange resins, employ chelating agents or  !

otherwise change the' solid radwaste characteristic '

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From this review, the inspector concluded that the licensee's Unit 1 annual sampling program were adequate for characterization of the Unit I radwaste stream . Radwaste Processing Licensee radwaste processing activities include sorting and packaging compactable and non-compactable waste materials, evaporation of moisture from borated and other chemical waste, dewatering of bead resin, solidification of precoat and powder resin materials and solidification of borated and other chemical waste concentrates and contaminated oil The licensee originally used the Urea-Formaldehyde (UF) process but has abandoned UF and gone to cement solidification supplied by a contracto The inspector reviewed licensee procedures, related Piping and Instrumentation Drawings, toured the. Unit 1 radwaste processing areas and interviewed licensee and contractor employees. In addition, the segregation of hazardous waste from radioactive waste was discussed with the Radwaste Operations Engineer, (NRC 1E Information Notice No. 87-03 responses). The licensee is developing administrative guidelines to centrol the entry of chemical products into Unit 1 areas in which there is a potential for contamination of the chemical by radioactive materia The resulting waste materials could be low-level radioactive waste under definitions in the low-level radioactive Waste Policy Amendments Act of 1985 and hazardous waste under EPA'S 40 CFR 261 Subparts C and Presently such " mixed waste" cannot be sent for disposal at the existing low-level waste site Within the. scope of this review, no problems or concerns were noted. The licensee's Unit I radwaste processing activities were consistent with regulatory requirements and the licensee appeared to be developing an administrative program to deal adequately with " mixed waste" material . Radwaste Generator Requirements The inspector reviewed the nine shipments selected against each of the following radwaste generator requirements:

Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);

Waste Classification under 10 CFR 20.311(d)(3) and 10 CFR 61.55; Waste Form and Characterization under 10 CFR 20.311(d)(3) and 10 CFR 61.56; Waste Shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR 61.55; Tracking of waste shipments under 10 CFR 20.311(d), (e), (f) and (h); and Adherence to disposal site license conditions for Agreement State licenses under 10 CFR 30.4 The basis for determination of waste class, (e.g. sampling, vendor analyses, computer modelling, accounting for hard-to-identify l

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radionuclides, dose rate to curie conversions and listing of named radionuclides under 10 CFR 20.311), was also reviewed and discussed with Radiological Engineering and other cognizant licensee personne :

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Within the scope of this review, no violations were noted. Good technical bases were noted for the classification of each of the nine-shipments. Appropriate quality control of waste form in dewatering'and solidification was also noted. The licensee was_ sampling, incorporating sample analyses into classifications and preparing waste manifests appropriatel . 9. - Radioactive Shipping Requirements The nine shipments were reviewed relative to criteria contained in 10 CFR 71 and 49 CFR 170-189 to determine if transportation requirements had been' me .1 Procurement and Selection of Packages The licensee's selection of packages for the nine shipments was reviewed relative to requirements in 49 CFR 173 and 10 CFR 71.1 Purchase orders and specifications.for " strong-tight" and specification containers were reviewed and found to contain regulatory requirements and specifications for material, coatings, labeling and testing. The licensee considered liners, drums and LSA boxes when purchased and receipt inspected as "important-to-safety."

Casks used'under a general license were also controlled and-inspected as "important-to-safety." Selection of packages for individual shipments was reviewed and found to be acceptable for the LSA, Type A and LSA greater than Type A activities involve Within the secpe of this review, no violations were note .2 Preparation of Packages for Shipment The licensee's preparation of " strong-tight" and specification packages for shipment was reviewed relative to requirements in 49-CFR 172 and 173, 10 CFR 71.87 and the licensee's procedure Shipping cask preparations were reviewed relative to 10 CFR 71.12 and individual Certificates of Compliance and accompanying document Performance relative to the criteria was determined by interviews of shipping personnel and examination of shipment records for the nine shipments reviewe No violations'were identified within the scope of this revie .3 Delivery of Packages to Carriers l The nine shipments were reviewed for compliance with placarding,

" exclusive-use," radioactive shipping record and public highway shipping. requirements (49 CFR 177). Actions taken in response to NRC IE Information Notice Nc. 87-31 were also reviewed. Discussions with shipping personnel and review of shipping records and procedures were used to determine the licensee's performance relative to the criteri _ _ _ _ _ - - - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

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i i No violations were identified within the scope of this revie .4 Transportation Incidents '

The licensee stated that no shipping problems, violations or  ;

I warnings were identified by the Agreement States during the period covered by this inspection for Unit I shipment . Exit Interview The inspector met with the licensee's representatives (denoted in l Detail 1) at the conclusion of the inspection on November 6, 1987.

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The inspector summarized the scope and findings of the inspection as i described in this repor At no time during the inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under i 10 CFR 2.790 is discussed in this repor l l

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