IR 05000293/1994008
| ML20029E807 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/06/1994 |
| From: | Bores R, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029E806 | List: |
| References | |
| 50-293-94-08, 50-293-94-8, NUDOCS 9405230008 | |
| Download: ML20029E807 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/94-08
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i Docket No.
50-293 j
License Nos. DPR-35
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Licensee:
Boston Edison Company Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth. Massachusetts 02360-5599 Facility Name: Pilgrim Nuclear Power Station
Inspection At: Pivmouth. Massachusetts Inspection Conducted: April 11-14.1994 Inspector:
'y.
0laf ( /19'{
J. Noggif SeniorI$fyation Specialist
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date Approved by:
bY t
l R. Bore's, Chi f, Facilities Radiation
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\\[date I
Protection ection Areas Reviewed: The inspection was an announced review of the radioactive waste / transportation program. Areas reviewed included: radwaste processing, waste stream sampling and analysis, preparation and shipment of radioactive material, existing on-site storage of radioactive wastes, and plans for future on-site storage of radwaste.
Results: The licensee's radwaste processing and shipping programs were considered strong with an experienced staff managing these activities. Improvements have been made in sludge storage tank decanting and in the development of a process control program. A design for an interim radwaste storage facility is approved. A partial spent fuel pool cleanout project i
9405230008 940509 PDR ADOCK 05000293 G
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was underway during this inspection to remove some radwaste items that had collected over several years. Minimal levels of stored radwaste were observed during the inspection. The trash compaction facility was found in need of repair. Remaining on-site radwaste and laidup radwaste equipment include: irradiated reactor hardware components in the spent fuel pool, and the floc recycle tank and radwaste concentrator equipment,
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DETAILS 1.0 Individuals Contqq1eil 1.1 Licensee Personnel
- J. Alexander, Nuclear Training and Management Services Manager
- J. Calfa, Senior Compliance Engineer
- L. Dooley, Technical Training Division Manager
- F. Famulari, Quality Assurance Division Manager
- C. Goddard, Nuclear Engineering Services Department Deputy Manager
- P. Hamilton, Licensing Division Manager
- P. Markson, Communications Specialist
- J. Moylan, Radwaste Division Manager (acting)
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- L. Olivier, Nuclear Services Manager
- W. Rothert, General Manager, Technical
- W. Stone, Maintenance Manager
- A. Williams, Station Services Section Manager (acting)
1.2 USNRC Personnel
- D. Kern, Resident Inspector
- J. MacDonald, Senior Resident Inspector
- Denotes those individuals attending the exit meeting on April 14, 1994.
2.0 t\\udits and Surveillances The licensee had discontinued the performance of routine annual radwaste/ transportation program audits in 1990 and had instituted a three-year surveillance program of 14 subject areas. The inspector reviewed thirteen surveillances conducted by the licensee during 1993 and noted only selected aspects of the program areas were reviewed and that a comprehensive review of the program was not obtained. Due to the new requirement for an annual audit of the radiation protection program (10 CFR 20.1101 (c)) instituted on January 1,1994, the licensee has reinstated an annual radwaste/ transportation audit requirement and the next subject audit is currently scheduled for June 1994.
The Radwaste Division has implemented a Waste Management Division Perfonnance Assessment Program since January 1994 that provides a checklist of progrmn areas to be used by radwaste supervisors in assessing various program areas on a periodic
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basis. This program is new and had few results for review during this inspection, however, this assessment program is a good initiative in its potential to provide a vehicle for self-evaluation and improvement by the radwaste staff.
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All radioactive material and radwaste shipment preparations were inspected and approved by the quality control group prior to the start of each shipment. Each radioactive shipment record reviewed by the inspector included a quality control checklist with appropriate signoffs completed by the quality control inspector.
The inspector reviewed three radwaste vendor audits with respect to applicable regulatory criteria and the licensee's procedural requirement for triennial vendor audit reviews. Chem Nuclear Systems, Incorporated (CNSI) Audit No. 30-92-07 was perfonned on hiay 5-8,1992 by the Nuclear Utilities Procurement Issues Council (NUPIC) and resulted in two findings involving control of "Q" suppliers. Both findings were tracked and dispositioned. Scientific Ecology Group (SEG) Audit No.92-505 was perfonned on March 27,1992 and resulted in three findings associated
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with laxness in the vendor's quality control progmm. The findings were similarly tracked and dispositioned. Vectra Technologies (fonnerly Pacific Nuclear) Audit No.
I AU-93-001 was conducted by NUPIC on November 2-4,1993. Three findings were reported that involved the safety-related classification of parts. In all cases, the licensee reviewed the vendor audits, tracked the audit findings and ensured the
appropriate corrections were made. The inspector did not note any discrepancies with j
the licensee's vendor audit program.
3.0
_Qrgani7ation i
The Station Services Section Manager (whose section includes chemistry, facility and-l radwaste functions) directs the Radwaste Division Manager. The Radwaste Division Manager has six radwaste supervisors that are responsible for the following areas:
radioactive shipments, operation of the trash compaction facility (TCF), radwaste operations, decontamination, hazardous material control, and sanitary waste treatment.
In addition, there are two specialists that report to the Radwaste Division Manager:
the Radwaste Systems Engineer and the Principal Radwaste Engineer. To complete the radwaste organization, there are 17 nuclear plant attendants who provide decontamination support and operate the TCF, and 10 nuclear auxiliary operators who operate the plant's liquid radwaste processing systems. At the time of this inspection, only one designated radioactive shipper was authorized by the licensee to dispatch radioactive material and mdwaste shipments. The organization continues to be stable with experienced personnel serving in the various positions.
4.0
'l'rpining
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The inspector reviewed the training records for the Radwaste Shipping Supervisor as the licensee's designated signatory for radwaste shipping manifests. The inspector reviewed training attendance records and verified that significant hazardous material training had been provided during the past four years. In addition, in late 1992 a
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radioactive material packaging and handling course was provided and more recently the Radwaste Shipping Supervisor had attended a RADMAN computer code certification course in August of 1993. The radioactive material packaging and
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i handling course was a 16-hour course given by the licensee to train the HP and radwaste staff to successfully prepare shipments and receive radioactive material shipments. The licensee had not provided the designated shipper with complete i
training in the appropriate NRC and DOT regulations. The Station Services Section Manager indicated that funher tmining was planned for the designated shipper to ensure a high quality of expertise in this area is maintained.
5.0 Radwaste Processing The Pilgrim Nuclear Power Station produces waste water from several sources and processes this water through various radwaste systems. Water from plant floor and equipment drains is filtered through diatomaceous canh flatbed filters and then de-ionized with resin bead radwaste demineralizers. The diatomaccous earth medium represents the first solid radwaste stream. The condensate and fuel pool cleanup systems also utilize resin bead demineralizers. The resin beads from the mdwaste, condensate and fuel pool cleanup systems constitute the second solid radwaste stream type. It should be noted that the licensee is in the process of installing an additional radwaste demineralizer vessel to provide for system flexibility. In particular, this new demineralizer may be utilized without prefiltering through the diatomaccous earth Dat bed unit. The installation of this 35-ft' demineralizer vessel should be completed later this year.
The reactor water cleanup system uses Powdex resin and this powdered resin represents the third solid radwaste stream. To further process the three wet solid waste streams, the licensee uses a NuPac (a subsidiary of Pacific Nuclear Systems, Inc.) high integrity container (HIC) dewatering and drying system to drive off any free standing liquid. This resin dewatering and drying procedure has been accomplished inside the radwaste tmcklock. For Powdex resin processing, the resin liner was traditionally staged in the nidwaste trucklock. and remained there for extended periods of time for the processing of this waste, because of the inability to properly decant liquid from the sludge storage tank prior to sluicing the Powdex resin i
into the resin liner. The licensee has recently installed a radiation monitor on the decant line from the sludge storage tank to allow the licensee to control the decanting of liquid waste to another tank and then sluice the remaining Powdex resin into the resin liner for processing within normal resin dewatering and drying time. T!ns modification resulted in minimizing the residence time and hence the exposure hazard period associated with spent resin storage in the radwaste trucklock.
A fourth waste stream is solid radwaste or day active waste (DAW). The clean and contaminated trash collected within the radiological controlled area (RCA) is shipped by scavan to Scientific Ecology Group (SEG) for segregation, survey, and
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incineration. After processing, the remaining radioactive material is shipped by SEG to the Barnwell Low-Level Radioactive Waste Management Facility in Barnwell, South Carolina for burial.
The inspector reviewed the licensee's program for sampling and characterization of solid radwaste streams. Scaling factors for all solid radwaste streams were detennined on a semi-annual basis by submitting composite radwaste samples to the Yankee Atomic Electric Company Environmental Laboratory for detennination of total isotopic content. The inspector verified the latest laboratory analyses were perfonned for the specified waste streams on August 9,1993, which is within the regulatory guidance for annual characterization of class B and C wastes and biennial sampling for class A wastes.
The licensee utilizes the RADMAN radwaste characterization computer software to detennine the radionuclide content of each radwaste shipment based on a three-part sample from each shipment that is analyzed for gamma-emitting isotopes. The licensee calculates the non-gamma emitting isotopes based on the sem.i-annual laboratory characterization analytical results, utilizing the RADMAN computer code.
The inspector reviewed the sampling and analytical records generated and detennined that the licensee effectively detennined the radionucFde content and appropriately classified radwastes for shallow land burial as specified in the applicable regulations.
The inspector reviewed the following mdioactive material handling, sampling, and radwaste characterizat'on procedures.
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Procedure No. 6.9-218, Rev. 4," Operation And Control Of The Trash Compaction Facility (TCF) And The Hazardous Materials Stomge Area"
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Procedure No. 6.9-211, Rev. 7,"10 CFR 61 Sampling"
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Procedure No. 6.9-222, Rev. 2," Control Of Radioactive Material Management Software And Data Bases"
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These procedures were found to be complete and in accordance with all NRC and Department of Transportation regulations.
In addition, the inspector reviewed a draft copy of new Procedure, No.1.15.3,
" Process Control Program", which provides the control parameters and regulatory limits associated with the processing of solid radioactive wastes in order to produce a radwaste product suitable for shallow land burial. This draft procedure was a good document and provides the basic criteria found in the NRC, DOT and burial site regulations. This procedure provides the radwaste pragram with objectives and provides a solid foundation and focus for the radwaste program. The inspecter noted
that _this document provides a consolidation of the requirements and criteria and should provide a significant program enhancement.
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6.0 Transportation l
The inspector reviewed the following radioactive material packaging, release and
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transportation procedures.
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Procedure No. 6.9-160. Rev. 28, " Radioactive Material Shipment Administrative Package Process"
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Procedure No. 6.9-174, Rev 8," Packaging Radioactive Material For Shipment"
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Procedure No. 6.9-194, Rev. 6," Loading Transport Vehicle For Radioactive Shipments" l
These procedures were found to be complete and in accordance with all NRC and Depanment of Transportation regulations.
The following shipment documentation was reviewed by the inspector.
Shipment No.
Activity (mci)
Volume (ft')
Waste Type j
93-18 4.8E5 132 POWDERED RESIN l
93-102
1280 METAL, DAW 94-05 1.4E4 202 DE'
l 94-06 1.4E4 202 BEAD RESIN 94-07 385 202 BEAD RESIN l
94-101 583 2560 TRASH, DAW l
94-204 23.I 1387 LAUNDRY l
l Diatomaccous Earth
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All shipping records were detennined to be complete and to meet the applicable requirements of 10 CFR Parts 20,61,71, and 73 and 49 CFR Pads 171-178. The i
inspector reviewed the shipping cask Certificates of Compliance and verified that all consignee licenses were on file as required. No safety concems or violations were identified.
7.0 Existine On-Site Radwaste Stomge l
The inspector reviewed with the licensee, the existing accumulation of radwaste and unused radwaste equipment to detennine if any unnecessary exposures or radiological
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I hazards were presented by the current mode of radwaste storage.
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7.1 Spent Fuel Pool At the time of the inspection, the licensee was conducting a spent fuel pool cleanout project. This project began on February 7,1994 and was expected to be completed on June 30,1994. The objective was to make additional room in the spent fuel pool to install additional fuel racks and increase the spent fuel storage capacity of the pool.
Most of the non-irradiated reactor hardware was in the process of being removed from the pool and packaged for shipment. The project was commencing smoothly without any safety concerns noted by the inspector. The irradiated hardware that will remain in the pool includes: 23 local power range monitors / dry tubes,25 control rod blades, and approximately 30 ft of miscellaneous material placed in storage boxes
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mounted on top of a fuel rack. This radwaste will require future disposal. The underwater storage of these components provided the necessary shielding and did not provide any unnecessary exposure to personnel.
7.2 Irash Compaclion Facility The trash compaction facility was reviewed by the inspector. The inspector noted that the facility was in need of repair. Several entry door doorknobs were broken and these outside doors could not be secured. These doors also exhibited through-door corrosion in places. The licensee indicated that the surrounding security fence provided secure control of the radioactive material inside the area. Several gutter downspouts were damaged or had missing sections and a number of damaged, unusable waste containers were found inside the fenced area. The Station Services Section Manager indicated that maintenance had already been scheduled to repair the doorknobs and downspouts and agreed to review disposition of any unsalvageable waste containers in this area.
Inside the trash compaction facility, the inspector noted that the floors had been freshly painted and a small quantity of radwaste was being stored in the facility.
Protective clothing laundry and trash collected from inside the radiological controlkd area were the main storage items. The licensee used this facility to store waste or used laundry until full shipments were accumulated. Less than a complete shipment of each was observed during this inspection. In addition,-the facility contained 22 drums of mixed waste, a small amount of spent fuel rerack tools and a partially filled radwaste liner containing some spent diatomaceous earth. The trash compaction facility contained minimal amounts of radwaste material and entry was controlled by a locked security gate to prevent unnecessary exposures. As previously mentioned, this facility was in need of maintenance.
7.3 Laiduo Radwaste Processing Eouipment The plant contains two rooms of mothballed radwaste processing equipment that are currently controlled as locked high radiation areas. The floc recycle tank room
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contains the floc recycle tank that was originally used to provide a floc precoat prior to powdered resin coating to the reactor water cleanup septum. The floc recycle tank was abandoned in 1978. The inspector reviewed a 1978 radiation survey that indicated tank contact radiation levels of between 125 and 150 rem / hour.
in 1976, the plant abandoned the use of a liquid radwaste concentrator for the processing of solid radwastes due to waste intmsions and multiple breakdowns. The licensee attempted to remove the concentrator equipment in 1985 and 1986, after which this work was abandoned. The work accomplished included removal of a compressor unit and an auxiliary boiler. The concentrator main tube bundle was removed from its vessel and the work had progressed into severing the tubes from the tube sheet when the work was stopped. Approximately 124 person-rem was expended by April 1,1986, and the technique of hand torch cutting of individual tubes then being used was deemed to be too manually intensive and too costly in terms of exposure to personnel. The inspector reviewed a 1986 radiation survey that indicated dose rates of 1.5-10 rem / hour at contact with the concentrator and general field readings of 200-330 mrem / hour.
Both the floc recycle tank and the radwaste concentrator represent laidup radwaste equipment that will require future removal and disposal actions by the licensee.
Neither area appeared to provide any radiological hazard and both areas were locked and appropriately posted to control inadvertent entry.
8.0 Interim On-Site Storage The licensee has approved a design plan for an interim low level radwaste storage facility on November 1992. Beginning July 1,1994, the licensee anticipates being restricted from off-site burial and will begin storing radwastes on site until a state-licensed burial site is opened.
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The licensee has some existing on-site storage capability. Currently there are 15 cylindrical concrete shielded containers on site that can accommodate approximately 6 months of plant-generated spent resin. Additional concrete containers can be obtained as required. The trash compaction facility is a large concrete building that cani accommodate approximately one year's worth of DAW. The licensee has approved plans for the construction of a 200-foot by 240-foot storage facility to bc located east of the trash compaction facility. The licensee estimates a 3-6 month construction period. The current design specifies a gravel pad that is surrounded by a ten-foot high shield wall. The shield wall consists of 4-foot thick hollow concrete panels filled with dirt. Inside this structure, individual radwaste storage containers are contained
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with individual cylindrical and rectangular concrete containers that are epoxy lined i
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and provide a sampling port for leak surveillance monitoring. The facility was designed for a maximum storage of 65,000 ft' of radwaste; a 5 mrem / year limit at the site boundary; one mrem / year limit to the closest member of the public; and 50
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mrem / year to occupationally exposed workers in the new engineering building at fully loaded capacity. The licensee generated 5,800 ft' of radwaste during 1993 and forecasts an average generation rate of 5,000 ft' annually. This indicates more than a 10-year potential radwaste storage capacity.
Due to the possibility that the Barnwell, South Carolina low-level waste disposal facility may continue to accept out-of-state waste after June 1994, the licensee has not set a construction schedule for the described interim radwaste storage facility. In the event that the burial site restricts the Commonwealth of Massachusetts from burial site access on June 30,1994, the licensee expects to utilize the existing on-site storage capability and begin construction of the facility at that time.
9.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1.0) on April 14, 1994. The inspector summarized the purpose, scope and findings of the inspection.
The licensee acknowledged the inspection findings, s
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