IR 05000315/1979026
| ML17318A608 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/27/1979 |
| From: | Fisher W, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17318A606 | List: |
| References | |
| 50-315-79-26, 50-316-79-24, NUDOCS 8002110334 | |
| Download: ML17318A608 (12) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTIONS AND ENFORCEMENT
REGION III
Report Nos. 315/79-26; 316/79-24 Docket Nos. 50-315; 50-316 License Nos.
American Electric Power Service Corporation Indiana and Michigan Power Company 2 Broadway New York, N.Y. 10004 Facility Name:
D.
C.
Cook Nuclear Plant, Units 1 and
Inspection At:
Site Inspection Cond c
d:q No ember 19-21, 1979 I
i Inspector:li k C.
Schemecher IA>
>
Approved By:
W. L. Fisher, Chief Fuel Facility Projects and Radiation Support Section Ins ection Summar Ins ection on November 19-21 1979 (Re ort No. 315/79-26.
316/79-24)
Areas Ins ected:
Special, announced inspection of radioactive waste systems, including:
effluent releases, records and reports of effluents, radioactive waste, response to IE Bulletin 79-19, and followup on pre-viously identified inspection findings.
The inspection involved 34 inspector-hours on site by one NRC inspector.
Results:
There were no i:tems of noncompliance identified in four of the five areas inspected.
An infraction was identified in the area of solid radioactive waste.
(Paragraph 6.a(7))
DETAILS 1.
Persons Contacted
="D. Shaller, Plant Manger-E. Smarella, Technical Supervisor
>D. Palmer, Radiation Protection Supervisor
-"T. Kriesel, Environmental Coordinator
"=J. Stietzel, gA Supervisor W. Scott, Environmental Engineer T. Beilman, Senior gA Auditor-Denotes those present at the exit interview of November 21, 1979.
2.
General This inspection, which began at 8:30 a.m.
on November 19, 1979, was conducted to examine licensee radioactive waste management practices.
Particular attention was given to the handling of wastes shipped offsite for burial, including licensee activities addressed in IE Bulletin No. 79-19,
"Packaging of Low-Level Radioactive Waste for Transport and Burial."
Relevant licensee records, procedures, and audits were reviewed and discussed with licensee representatives.
Radwaste processing facilities were inspected.
Two previously packaged drums, one containing compressed trash and the other containing spent filter elements were opened.
Also examined were two open cylinders containing urea formaldehyde solidified evaporator bottoms which were being tested for standing free water.
No dewatered resins were being handled during the inspection.
There was no opportunity to examine any outgoing shipments.
3.
Iicensee Action on Previous Ins ection Findin s (Closed) Infraction l. (315/79-14):
Failure to adequately evaluate contractor internal exposure as required by 10 CFR 20.103(b)(2).
Corrective action stipulated in the licensee's letter of July 24, 1979, was confirmed.
(Closed) Infraction 2. (315/79-14):
Failure to take suitable air samples to evaluate iodine exposure as required by 10 CFR 20.103(a)(3).
Corrective action stipulated in the licensee's letter of July 20, 1979, was confirmed.
4.
Radioactive Effluents a.
Airborne Releases Discussion with licensee representatives revealed that the methods for quantifying airborne releases have not changed since the last
radwaste inspectio Batch releases (gas decay tanks and 1/
containment purges)
are sampled before release via the plant vents.
Continuous releases via the vents are sampled continu-ously for iodines and particulates; weekly grab samples are taken for noble gases.
The inspector compared selected batch releases for the first quarter of 1979 with quantities reported in the semiannual report.
No significant discrepancies were noted.
No items of noncompliance were identified.
The inspector reviewed selected records of 159 batch releases made during the first and second quarters of 1979.
Cesium-137, iodine -131, and tritium activities in the individual batches were accurately reflected in the licensee's semiannual report.
No items of noncompliance were identified.
5.
Records and Re orts of Effluents The inspector reviewed the semiannual reports for the second half of 1978 and the first half of 1979 for internal consistency and made selective comparisons with licensee's batch release records'o significant discrepancies were noted.
No items of noncompliance were identified.
6.
Solid Radioactive Waste Solid radioactive waste handling, including licensee actions in response to IE Bulletin 79-19, was reviewed in detail during this inspection.
a.
IEB 79-19 "Packa in of Low-Level Radioactive Waste for Trans ort and Burial The following comments are numbered consistent with the topics addressed in the bulletin.
(1)
The licensee possesses an adequately maintained set of current NRC and DOT regulations furnished by the Datamation Inc. Services.
(2)
The licensee possesses a copy of the current (October 30, 1979) license issued by the State of South Carolina to Chem-Nuclear Systems Inc. for the Barnwell burial site and 1/
Region III Inspection Report No. 315/78-28
l l
a copy of the State of Maryland License No. MD-27-001-02 issued to Hittman Nuclear Development Corporation.
Responsibility for handling of radioactive wastes is de-signated in Plant Manager Instruction (PMI) No. 3150, (Rev. 2, March 6, 1979).
These instructions assign responsi-bility for shipment of radioactive material to the Adminis-trative Supervisor'nd by subsequent delegation to the Stores Supervisor; responsibility for providing technical direction related to health physics is assigned to the Technical Superintendent and by subsequent delagation to the Plant Radiation Protection Supervisor.
The designation of the Administrative Supervisor is misleading as his respon-sibility appears limited to maintaining a copy of the records of all shipments.
PMI 3150 and the related Technical Department Head Instruction (THI) No.
3150 (Rev.
1, October 11, 1979) designates responsibility for inspecting packages, re-cording shipping information pursuant to DOT regulations, and ensuring that Procedure RAD 304,
"Shipment of Radioactive Materials," is followed to the Plant Radiation Protection Supervisor.
The licensee's response to IE Bulletin 79-19 notes the involvement of several plant departments in following procedures for packaging and transport of wastes, with each supervisor having responsibility for seeing pro-cedures are followed, with ultimate responsibility falling to the Plant Radiation Protection Supervisor.
In practice, the responsibility appears to be shared equally by the Environmental Supervisor, who is not mentioned in the above cited instructions.
He reports independently to the Technical Department Supervisor and is responsible for overseeing solidification of evaporator concentrates by contractor (Hittman Nuclear) personnel, for directing pre-paration of spent resins for shipment, and for certifying to the State of South Carolina that the shipment meets burial requirements.
The need for more accurate definition of responsibilities was identified by a corporate level QA audit conducted in October, and was discussed in the exit interview following this inspection.,
As indicated in the licensee's response, there are procedures dealing specifically with packaging and shipping of low-level wastes.
These are:
RAD 303, "Solid Waste Handling and Drumming,"
~ ~
II
RAD 304,
"Shipment of Radioactive Materials," and Special.014'Resin Transfer from the Spent Resin Storage Tank to a Cask."
These approved procedures are implemented by members of the radiation protection and/or environmental groups, which either perform or oversee performance of the work.
However, certain aspects of solid waste handling are not fully covered by detailed procedures.
These include:
(a)
evaporator concentrates solidification with urea formaldehyde (UF), including assurance of no free-standing water; (b)
cask inspections and closure procedures; (c)
truck loading and final shipment inspection procedures; (d)
procedure for estimating resin activity; and (e)
procedure for training/retraining on waste packaging and shipment.
Spent resin is packaged and dewatered under direction of the environmental group, following Special
.014.
Dewatering is accomplished by pumping until no more flow is obtained from well points laid on the bottom of a liner.
The liner is then capped and the cask closed for shipping.
The licensee believes his dewatering procedure to be effective, but agreed to make further tests before shipping to ensure that there is no significant further accumulation of water after the package is allowed to stand for a period of time.
He also stated that the maximum amount of water that could not be removed by his dewatering method would be determined.
The inspector was informed on December 10 that this amount was calculated to be lg and that the dewatering method was being modified slightly to achieve 0.35/ residual.
He was also informed of an ongoing test that showed an additional removal of 0.5'/, water 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after dewatering and an additional 0.33/ at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
These data suggest that careful dewatering can hold residual unbound water to below 1'/ by volume.
The licensee's examination of this problem is continuing and his dewatering procedure will be modified to reflect the results.
Resin activity (millicuries) is determined from a survey in-strument reading taken directly above the open cask top at a
point 3 feet above the resin surface.
Isotope distribution is gotten from gamma spectrometry performed on a small sample
of resin.
Total activity calculated from the normalized spectrometry data (millicuries per gram or millicuries per bead)
gave good agreement with survey data for two of the three casks shipped in 1979.
In the third case, the survey method was about a factor of 30 lower (15 Ci vs 400 Ci).
The licensee agreed to resolve this problem.
Concentration of transuranics in the resin is less than 0.01/ at the burial site limit of 10 nCi/g, according to analyses performed by a licensee contractor.
Urea formaldehyde (UF) solidification of evaporator bottoms is done by Hittman Nuclear Development Corporation (HNDC) tech-nicians, under the general oversight of the station environ-mental group.
The licensee does not have procedures covering the actual solidification process, but relies on the knowledge of the HNDC technicians.
Licensee representatives stated that HNDC has agreed to furnish solidification procedures for in-corporation into the licensee Process Control Procedure (PCP)
under development.
Environmental group personnel are directly involved in the dewatering of the solidified UF product.
This consists of tilting a filled container (1000 or 1500 gallons)
toward a bung at the bottom of one end and observing until no moisture is seen through the opened top and none drains from the bung.
Plant Manager Standing Order (PMSO) No.
40 (9/7/79) requires that a
free water check be made three days after solidification, that no shipment be made before four days, and that no free water be shipped.
In practice, licensee personnel said that water has been seen as late as two weeks after solidification, that the pattern of water flow was unpredictable, and that ten days was the earliest time at which they have been able to ship.
This activity is not covered by a detailed procedure.
Activity solidified is determined by gamma spectometry on a
sample of evaporator concentrates.
Transuranic and strontium 90 analyses have not been done fox concentrates, but licensee representatives reckon their concentration to be no higher than that seen on resins.
The licensee agreed to confirm this estimate.
Licensee procedures do not cover, in detail, cask handling (inspection, maintenance, loading and unloading),
package load-ing onto trucks, or final inspection of outgoing shipments.
Some aspects are covered in RAD 304 and Special
.014, but check lists are not provided and detailed cask handling procedures of the cask vendor are not incorporated.
The procedure inadequacies were, for the most part, identified in the licensee's October audit.
In response, site personnel
are preparing a Process Control Procedure (PCP) for solid waste handling and a cask handling procedure.
Licensee representa-tives stated that these and other procedures, as needed, would address the areas identified.
The October audit noted the absence of radwaste training for plant maintenance personnel and the unknown training and apparent inexperience of Hittman solidification workers.
The station regards the use of equipment for rigging and handling of heavy containers as falling within the craft skills of maintenance personnel.
On October 29 and 31, training on regulatory require-ments and plant radwaste procedures and instructions was given to 25 people from the technical department and to contractor personnel (Eastern Cleaning Equipment Corporation and SCOPE)
who work with radioactive trash.
The training did not include testing on the material presented.
Licensee representatives indicated that the training would be expanded to all persons directly involved with radwaste handling, and would be repeated annually.
The October audit noted that there is no training to ensure that low-level waste volumes are minimized.
Licensee representatives stated there have been some discussions on this matter, and that the training would be given to personnel involved in generating such wastes.
Licensee response to IE Bulletin 79-19 stated that an audit function had been established under cognizance of the corporate Nuclear Safety and Design Review Committee (NSDRC).
This was confirmed by the inspector.
Before IE Bulletin 79-19, however, the licensee had no established audit function for transportation of radioactive materials.
Further, it appears the licensee had not established, maintained, or executed a quality assurance program for packages and for shipping low-level wastes, and had not submitted a description of such a program by January 1,
1979, with the director, NMSS.
This failure appears to be noncompliance with 10 CFR 71.51.
The licensee has a
QA program under Appendix B to 10 CFR 50, but there was no evidence that it had been applied to packaging and shipping of radioactive wastes.
An interim audit by onsite gA personnel was done September 25-27, 1979, and a more intensive NSDRC audit was done on October 3-4, 1979.
Both audits were done within 60 days of IE Bulletin 79-19 (August 19,1979).
The final report of the October audits was not on file, but a copy of the results was transmitted to the site for inspector review during the inspection.
- 7-
Licensee representatives stated that corrective actions related to the audit findings were targeted for completion by the end of the first quarter of 1980.
(9)
Information on activity and volume of low-level waste shippe'd was obtained from the licensee's Semi-Annual Effluent Release Reports and from discussion with licensee personnel.
Spent Resins Evaporator Bottoms Trash Total Period Ci M
Ci M Ci M 1/1/78-12/31/78 205 933 21 337 226 1275 1/1/79-6/30/79
401="
143 29 544
+Erroneously reported as 1.42E4M
.
Errata to be submitted
with next semiannual report.
Re orted Discre anc in Shi ment to Barnwell In July 1979 Region III received a discrepancy report issued by the State of South Carolina describing a dewatered resin shipment made by the D.
C.
Cook plant on April 26, 1979.
The report stated the cask (Hittman HN-100s) contained 30 gallons of water, in viola-tion of the Barnwell license.
When the matter was brought up dur-ing this inspection licensee personnel indicated they had not been informed of the occurrence, but planned to discuss the matter with Barnwell representatives during the visit, there by a Cook employee.
On November 29, 1979, the inspector was informed that Barnwell personnel had indicated the water was found in the cask outside the liner intended for burial.
He was also informed that discrepancies noted at Barnwell would henceforth be communicated directly to the environmental supervisor.
Iicensee shipping records for the shipment appeared in order.
The package was a spent demineralizer containing 0.4 curies of spent resins.
There was no evidence that the water was associated with the burial liner.
However, the licensee could not state with con-fidence that the water had not been in the cask before leaving the Cook site, because there was no documented inspection of the cask when it first arrived nor when it left for Barnwell.
Barnwell License Condition No.
25 (South Carolina License No.
097, Amendment 26) prohibits receiving liquid waste, regardless of chemical form, and requires that there be no detectable free-standing liquids.
The license transmittal letter (October 30, 1979), defines
"no free-standing liquids" as less than 1/ by volume.
Thirty gallons in a package volume of 170 cubic feet is 2g,.
-8-
This matter is considered an unresolved item, pending IE head-quarters resolution of the question of whether the licensee is in noncompliance with 10 CFR 30.41.
c.
Onsite Examination of Packa es No radwaste packaging was being done at the time of this inspection.
Therefore, there was no opportunity to observe spent resin packaging and dewatering.
Two packaged drums were selected by the inspector for opening.
One contained compacted waste and one contained un-compacted waste filter elements as indicated in the Licensee's drummed radwaste log.
Both packages appeared to meet requirements for shipping, except that the Radioactive I,SA label had not been applied.
Licensee personnel stated these labels are applied at time of final survey and truck loading.
The inspector was also told that in the future drums would be obtained prelabeled.
The inspector also examined two 1500-gallon horizontal cylinders containing UF solidified evaporator bottoms.
They were tilted to permit draining through a bung at one end, into a container.
I,arge ports in the top of the cylinders were open.
The solid had apparently contracted, as there was a large void space at the top of the horizontal cylinder and there were gaps between the cylindrically shaped solid and the container walls.
The surface showed no evidence of moisture; it crumbled and remained dry in appearance when probed vigorously with a rod.
Licensee personnel indicated that such probing and inspection of the sur-face is a normal practice used in confirming that freestanding water is not shipped.
7.
Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations.
An unresolved item disclosed during this inspection is discussed in Paragraph 6.b.
8.
Exit Interview The scope and findings of the inspection were discussed with Mr. Shaller, Plant Manager, and others of his staff (denoted in Paragraph 1), at an exit interview on November 21, 1979, and in telephone conversations on November 27, 28, and 30, and December
and 10, 1979.
One item of noncompliance for failure to have a quality assurance program for transport packages (Paragraph 6a(7))
and one unresolved item concerning a cask containing water inecess of burial site limits (Paragraph 6b) were describe Mr. Shaller expressed concern that the plant-had not been notified earlier of the cask problem.
On November 29, 1979, the inspector was informed by licensee personnel that arrangements had been made for direct notification from the burial site.
The licensee agreed to take additional steps to confirm that dewater-ed resins meet burial site criteria before any further shipments are made.
On December 10, 1979, the inspector was informed of modifica-tions made to the dewatering apparatus to ensure that the lower limit of dewatering is below lg and of tests being done to confirm that any further water accumulation after dewatering is insignifi-cant.
These tests will re reviewed during a subsequent inspection (Paragraph 6a(4)).
The licensee stated that corrective action for weaknesses concerning ambiguous respnsibilities (Paragraph 6a(3)),
incomplete procedure coverage of radwaste activities'(Paragraph 6a(4)),
and training (Paragraph 6a(5)) noted during this inspection and the NSDRC corporate audit would be scheduled for completion during the first quarter of 1980.
10-