IR 05000309/1987023

Safety Insp Rept 50-309/87-23 on 870921-25.No Violations or Deviations Noted.Major Areas Inspected:Solid Radwaste Processing,Preparation,Packaging & Shipping Program, Including Mgt Controls,Qa/Qc & Radiochemistry

ML20236K334
Person / Time
Site:	Maine Yankee
Issue date:	11/03/1987
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236K323	List: IR 05000309/1987023 ML20236K319
References
50-309-87-23, GL-81-38, IEB-79-19, IEIN-84-50, IEIN-86-020, IEIN-86-20, IEIN-87-003, IEIN-87-007, IEIN-87-3, IEIN-87-7, NUDOCS 8711090194
Download: ML20236K334 (11)

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I U. S. NUCLEAR REGULATORY COMMISSION i

REGION I

Report No. 87-23

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Docket N )

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l License N DPR-36 P Priority -- Category C Licensee: Maine Yankee Atomic Power Company 83 Edison Drive liIgusta, Maine 04436 Facility Name: Maine Yankee Nuclear Generating Station I

Inspection At: Wiscasset, Maine Inspection Conducted: September 21-25, 1987 Inspectors: \MS.hw se. Radiation Spec 14 Qst Nw 3, date

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H. Bice Approved by:

WVPasciak, Cfiief

__Nbt 6'V N 3 h date Effluents Radiation Protection Section i

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In.spection Summary: Inspection on September 21-25, 1987 (Report N ~50-309/87-231 l Areas Inspected: Routine, unannounced safety inspection of the licensee's solid radicacthe waste (radwaste) processing, preparation, packaging and shipping prograrh including previously identified items, management control;,

quality assurance / quality control, radiochemistry, radwaste processes, radwaste generator and radioactive materials shipping requirement _Results: No violations were notad. The licensee was implementing a generally effective program in the areas examine oj94 B71105

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DETAILS

.1. Persons Contacted 1.1 Licensee Personnel A. Bonefant, Quality Control Inspector

• E. Boulette, Ph.D. Assistant Plant Manager D. Boynton, Reactor Engineering Section Head

• J. Connell, Assistant to Technical Support Department Manager P. Dostie, Lead Specialist-Radwaste Functions

• J. Garrity, Plant Manager  ;

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M. Herrin, Durotek Technical Representative

• R. Lawton, Manager, Quality Assurance

• G. Pillsbury, Radiological Controls Section Head P. Radsky, Chemistry Section Head

+R. Wills, Radiological Control Supervisor (Former Hazardous Waste Coordinator)

Other licensee personnel were also contacted or interviewed during the course of the inspectio .2 NRC Personnel R. Freudenberger, Resident Inspector

• Holden, Senior Resident Inspector

• Attended the exit interview on September 25, 198 . Scope of the Inspection This routine safety inspection reviewed the licensee's solid radioactive waste (radwaste) processing, preparation, packaging and shipping program (as implemented by the licensee) from May 9,1986 through September 25, 3 1987. During that period, the licensee made 12 shipments of solid I radwaste. From May through December 1986, the licensee shipped 3,838  !

cubic feet (totalling approximately 89.29 curies). From January 1,  !

through September 25, 1987, the licensee made 4 shipments (totaling 2,491 cubic feet and approximately 184.66 curies). No shipments had been made i since June 16, 1987 following the transfer of the Hazardous Waste Coordinator to operational radiation protection dutie The 12 shipments were reviewed relative to requirements in 10 CFR 20.311, 10 CFR 61.55-56, 10 CFR 71, 49 CFR 170-189 and the licensee's technical specification >

In addition, changes in radwaste characteristics caused by fuel failures .

and radwaste processing were also reviewe !

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l' Previously Identified Item -

l l (Closed) . Violation (50-309/86-06-01) Failure to-identify Iron-55 on i radwaste manifest. The licensee completed actions as described in the

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licensee's: letter (dated July 28,1986) in response to the NRC Notice.of-Violation. The licensee changed criteria in procedures to require individual listing for any. radionuclides totaling more than 1% of the shipment's total activit Review of radioactive shipping records showed <

that-the licensee had implemented-the changes in subsequent shipment This item is close .. Management Controls 4.1 Organization The organizational structure of the licensee's solid radwaste j processing, preparation, packaging and shipping activities were !

reviewed relative to Final Safety' Analysis Report (FSAR).and . j technical specification commitments and requirements. Oversight o i contractor activities (NRC IE Information Notice 87-07) was als . l reviewed. Within the Radiological Controls Section of the Technical ~ j Support Department, the Hazardous Waste Coordinator coordinates -

effort by the various plant departments,'(e.g. Operations, Technical !

Support,.etc.) to process, prepare, package and ship solid radwaste !

materials. The 0perations Department provided supervision and .'

resources needed to process to completion alll liquid radwaste and process filters. The Plant Services Department provided supervisio and resources to sort dry active waste-(DAW), compact or otherwise J prepare' DAW, support all shipments and support disposal of- 1 non-radiological hazardous waste. The Maintenance. Department i provided supervision and resources to process radwaste generated b maintenance activities, support radwaste shipments and decontaminate equipment as necessary. The Hazardous Waste Coordinator provided technical support and quality control .to the other departments and ;

technical oversight and coordination for contracted radwaste l operation .J Within the scope of the review, the inspector noted that the Hazardous Waste Coordinator position was open. The previous incumbent had been promoted and transferred to an operational radiation protection supervisory position. Discussions with the

.v . licensee indicated that a replacement was being sought and radwaste shipments weren't planned until 1988 (allowing time for a suitable replacement to be found). The inspector discussed the need for early selection and appointment of a Hazardous Waste Coordinator to provide technical continuity to the solid radwaste progra I

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4.2 Procedures -

The licensee's procedures for processing, preparation, packaging and shipping solid radwaste' materials were reviewed relative to criteria provided in 10 CFR 20.311, 10 CFR 71.5, 10 CFR.71.12 and the licensee's Technical Specification The following procedures were reviewed, discussed with the licensee and checked far implementation:

9.1.13 " Transfer and Storage of Radioactive Waste Containers in the Low Level Waste and Equipment Temporary Storage Building," Revision 1 (1/86);

9.1.14, " Receipt of Radioactive Material," Revision 10 (1/87);

9.1.15, " Shipment of Radioactive Material," Revision 19 (1/87);

9.1.17, " Radiation Protection Requirements for Radioactive i

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Waste Processing, and Shipping," Revision 10 (2/87);

9.1.21, " Preparation of Radioactive Solid Waste for Disposal" Revision 3 (2/87); and 9.1.29, " Quality Control for Radioactive Waste Program,"

Revision 1 (2/87).

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Within the scope of this review, no violations were note However, the following weaknesses were noted and discussed with the licensee:

The licensee used a tedious method of hand calculations for radwaste classification under 10 CFR 20.311 and 10 CFR 61.5 No independent verification of the waste classification calculations was required by the procedures to reduce the chances for errors in those calculations and subsequent classifications. Although no errors in classification were 1'

noted in the 12 shipments reviewed, improved review of the calculations should be considere Licensee's procedures did not provide criteria for resampling (

radwaste streams for changes in plant operating parameters j potentially affecting the mix of radionuclides in those i streams. Fuel failures, changes in insoluble Reactor Coolant I System (RCS) fraction (" CRUD"), new radwaste processes ( ion exchange resins used in place of evaporators and decontamination resins used for collection of radwaste l materials in the "LOMl" process), etc. require additional (and different) samples to recharacterize the affected waste strea !

Procedures should indicate what needs to be sampled and provide I a systematic evaluation of sample results for technical i adequacy and representativeness. Although the licensee l appeared to have taken samples appropriately, obtained vendor analyses and implemented technically-correct scaling factors for the shipments reviewed, licensee procedures did not provide guidance for those additional samples and analyse . _ _ . _ _ _ _ _ _ _ _

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.The inspector also reviewed the licensee's methods for controlling procedures used by contracted dewatering, solidification and alternate radwaste' processing vendors. The licensee routinely

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reviewed the vendor procedures and accepted the procedures as controlled plant procedure .3 Indoctrination and Training The licensee's indoctrination and training program, (as it related to solid radwaste processing, preparation, packaging and shipping activities), was reviewed relative to commitments in the licensee's response to NRC IE Bulletin No. 79-19. Training, provided to selected Radiological Controls, Operations, Plant Services, Quality Control and Quality Assurance personnel was reviewed with Training personnel, discussed with selected individuals in the groups trained and training records were briefly examined. In 1986, the Hazardous Waste Coordinator attended a vendor-supplied 3-day regulatory awareness course. Two Quality Control inspectors also attended that training cours ,

Within the scope of the review, no deviations from commitments to NRC IE Bulletin No. 79-19 were noted. However, the following '

apparent weakness was discursed with the licensee. Operations and Maintenance personnel interviewed showed little awareness of the problems caused to solid radwaste operations by the introduction of fluids into the liquid radwaste processing system. Anti-corrosion agents, (e.g. chromates), oils and other organic materials have been introduced into the liquid radwaste system and caused significant processing problems. Solid radwaste volume reduction efforts were also not well communicated with the individuals interviewe . Quality Assurance / Quality Control Specific quality control requirements are mandated by 10 CFR 20.311 to 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, 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. 84-50. 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 I

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control program to the licensee' responsibilities as a solid radwaste generator.and shipper was reviewe .1 Waste Generator Quality Control / Process Control Program Licensee's and-accepted vendor's procedures were reviewed to

' determine if appropriate quality control checks were included to ensure proper classification of radwaste shipments under 10 CFR 61.55 and proper radwaste form under 10 CFR 61.56, (See related item Detail,4.1). For the 12. shipments reviewed, implementation of procedural holdpoints and other quality; control verifications was reviewed and discussed with quality control and quality assurance personnel. Yankee Atomic Audit No. MY-86-09, "Radwaste," (August 4-8,1986) was reviewed to determine its inclusion of attributes related to 10 CFR 61.55-56 compliance, licensee management review of !

that audit and resolution of findings and recommendation Excepting verification of classification calculations, the inspector noted that appropriate inspection holdpoints were provided in the procedures and had been implemented for the shipments reviewed by quality control personnel suitably knowledgeable. Audit No.MY-86-09 adequately covered attributes of 10 CFR 61.55-56 and had received appropriate licensee management review and' resolution of finding Within the scope of this review, no violations were noted. The licensee was implementing a generally effective quality' control program under 10 CFR 20.31 .2 Radwaste Shipper Quality Control / Quality Assurance Licensee's procedures were reviewed to determine quality control attributes verified in receipt inspections of transport package Examination of shipping records verified implementation of those ,

procedure Shipping records were also reviewed and discussed with j the licensee to verify quality control inspection of applicable items of the packaging's Certificate of Compliance. The licensee ,

conducted semiannual surveillance of ongoing activities in the Quality Assurance Surveillance progra Audit No MY-86-09 was reviewed for inclusion of attributes need to ensure compliance with 10 CFR 71. The inspector noted that the technical specialists assigned to that audit were qualified in radioactive materials shipping and radwaste generator requirement Within the scope of this review, no violations were note The licensee was implementing a quality control / quality assurance program in general agreement with guidance provided in NRC IE Notice No. 84-5 I

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' : Radiochemistry The inspector briefly reviewed licensee fuel. performance, ion exchange

resins and filters, RCS chemistry operation.and decontamination efforts to determine the general adequacy of the licensee's' sampling and vendor; analysis program-for difficult-to-identify radionuclides. Possible changes limited to req)uiring

- additional sampling and analysis include (but are not

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(1). substantial changes-in fission-product concentrations in the reactor

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coolant ,(fuel failure) but little or no change in activation product concentrations;-

(2) substantial increases in activation-product concentrations in the reactor coolant (resuspension of solids in the system) but little or

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no change in fission product concentrations;

,(3) Increases in both fission and activation product concentrat-fons;

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.(4) Radwaste' equipment or processes are put.into service.for which no scaling data'are available. (See Detail 7.2).

In November 1985, the licensee experienced fuel failure in four fuel rods in three different bundles.: In one fuel bundle, two' fuel rods faile Those failures were attributed to incore debris-induced' clad thinning and subsequent-hydriding of the Zircalloy once the cladding was breache The remaining two fuel rod' failures were believed to'have resulted from hydriding alon The licensee generally follows the Nuclear Steam Supply System vendor's recommendations for primary water chemistry control including the 1-2 ppm ~

lithium operating scheme, conventional ion exchange' resins in the purification system. and no deliberate insoluble bring out at the end of cycl The licensee used a low-oxidation state metal ion ("LOMI")

decontamination of the Number 2 Reactor Coolant Pump impeller and collected the displaced radioactive material, chelating and treatment >

agents on special ion exchange resin l l 'Radwaste Processing 7.1 Low-Level-Radwaste Facility The licensee has constructed a temporary low-level radwaste storage facility to provide up to five years of on-site storage. The stored  ;

radwaste is packaged in shipping containers that are ready for final

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. shipment. The licensee has reviewed and approved the facility for ,

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storage of compacted dry waste, solidified' evaporator bottoms and resins, contaminated equipment and reusable shielding material No .

radwaste is processed or sorted in the facility. The design, l construction and operation of the facility were reviewed against 1 criteria and guidance provided in:

10 CFR 20.106, " Radioactivity in Effluents to Unrestricted Areas;"

10 CFR 50.59, " Changes, Tests and Experiments;"

10 CFR 100, " Reactor Site Criteria," (as modified in NRC-NRR ,

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Generic Letter. 81-38); and I NRC-NRR Generic Letter 81-38) and its enclosure entitled

" Radiological Safety Guidance For Onsite Contingency Storage I Capacity."

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Design criteria and licensee safety evaluations were reviewed. The inspector noted that the facility's design, safety analysis and operating procedures had been reviewed and approved by the Plant Operations Review Committee (PORC) in a series of meetings. The licensee concluded that operation of the facility did not create an unreviewed safety question (as defined in 10 CFR 50.59) and its ,

operation did not involve a change in the licensee's Technical 1 Specification l l

Review of the facility showed that no radwaste material, greater I than Type A quantities were stored in the building. Routine surveys j were conducted by radiological controls technicians and quality j control inspectors verified container integrit Radioactive l material inventories were maintained in logs and no radioactive )

effluents resulted from facility operation j l

Within the scope of this review, no problems or concerns were note ]

7.2 Durotek Process  !

The licensee has installed a Durotek Demineralization System as a vendor-supplied alternative treatment for radioac^1ve wt te water in place of evaporator operation. Prior to the installation, borates '

l in the evaporator bottoms could not be solidified in cement (if the borates were greater than 14 % by weight). The alternate

demineralization system removes radioactive materials from the liquid radwaste by filtration and deionization. Filter media and

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resins used in the process are either solidified or dewatere ,

l Volume and cost reductions have been realized by the licensee !

through use of this proces l

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Installation and operation of the system were. reviewed by PORC in 1986 and approve The licensee concluded that operation of the system did not create an unreviewed safety question and its operation did not require a change in the licensee's Technical'

Specification Within the scope of this review, no violations were note .3 Other Radwaste Processing The inspector reviewed the licensee's sorting and compacting of dry active waste, licensee and vender-supplied resin dewatering, vendor- ]

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supplied solidification of resins and segregation of hazardous wastes from radwastes (NRC IE Information Notice No. 87-03). The licensee had instituted a segregation program to ensure separation of hazardous wastes and separate disposal. Although no violations were noted in this review, the inspector noted that chromates used as corrosion inhibitors in the Primary and Secondary Cooling Systems could be introduced into the solid radwaste stream as evaporator i bottoms or entrained in Durotek resins via the aerated drain tan The licensee was instituting administrative controls to prevent introduction of chromates into the pumps and drains, including use ;

of drums and barrels for draining the Primary and Secondary Cooling i System f 8. Radwaste Generator Requirements The inspector reviewed the 12 shipments made by the licensee against each of the following radwaste generator requirements:

Waste Manifests under 10 CFR 20.311 (d) (4) and 20,311 (b) and (c); j

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, scaling factors for hard-to-identify radionuclides, and calculations) was also reviewed for each shipment relative to the guidance in the Branch Technical Positio Within the scope of this review, no violations were note Good technical bases were noted for routine shipments and LOMI resin classification. The licensee took appropriate samples, updated scaling factors and implemented changes to the classification program in response to fuel failures and other changes noted in Detail 6. Appropriate quality control for waste form was also note _ _ _ _ _ _ _ _ - - - - .- l

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[91- Radwaste Shipping Requirements The,'12 shipments were' reviewed relative to criteria contained in 10 CFR

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H . 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 12 shipments was reviewed relative to requirements in'49 CFR 173, " Shippers-General Requirements;for Shipments and Packaging," and 10 CFR 71.12,-

" General License: NRC Approved Package." The licensee's performance. relative to the criteria was determined by review of pro::edures and radioactive shipping record Within the scope 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 documents. Performance relative to these criteria was determined by

, interviews of cognizant licensee personnel. and ' examination of '

l radioactive shipment record No violations were noted within the scope-of this revie <

9.3 Delivery of Packages to Carriers The delivery of packages to carriers was reviewed for compliance

with placarding, (49shipping manifests under 10and CFRpublic highway (iii),ship (pingiv) and

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requirements CFR 177) 71.5 (a)(1)  !

(vi). Actions taken in response to NRC IE Information Notice N were also reviewed. Review of shipping records and discussions with licensee personnel were used to determine the licensee's performance relative tn the criteri Within the scope of this review, no violations were identifie .4 Transportation Incidents

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The licensee stated.that no shipping problems were noted for the 12 shipments. The licensee had received a warning from a State Regulatory Agency (although no violations were noted) for not including certain radionuclides (specified in 10 CFR 20.311(b)) on other then the first sheet of the manifes The State Regulatory Agency indicated that the radionuclides had to be included on each

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• . continuation sheet'for each packagec of dry active waste 'although -

their calculated activities were each less_ than 1% of that. package's

, total activity. 'The licensee has modified procedures to comply with

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10.- Exit Intervie' .

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.The inspector met with the : licensee's representatives' (denoted in ' Detail 1) at the conclusion of the inspection on September'25, 1987. 'The

. inspector summarized:the. scope and findings;of the-inspection as -

described in this report.- ,  !

- At no . time during.the: inspection was written material provided to the

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licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this repor !

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