IR 05000317/1979022
| ML19294B427 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/09/1980 |
| From: | Crocker H, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19294B422 | List: |
| References | |
| 50-317-79-22, 50-318-79-21, NUDOCS 8002280345 | |
| Download: ML19294B427 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-317/79-22 Report No. 50-318/79-21 50-317 Docket No. 50-318
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Category C
License No. DPR-69 Priority
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Licensee: Baltimore Gas and Electric Comoany P. O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Station, Units 1 and 2 Inspection at: Lusby, Maryland Inspection conducted:
Deced6pr 6 1979
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Inspectors:
k
/ / 8[
J. R.
ite, Radiation Specialist
/ dat( signed date signed j
date signed c-Approved b 484 M
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/ /9'M8 Acti ng, Chief,Wdiation Support
'/ date signed
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Section, FF&MS Branch Inspection Summary:
Inspection on December 6-7, 1979 (Combined Reoort Nos. 50-317/79-22 and 50-318/79-21 Areas Inspected:
Special, unannounced inspection by a regional based inspector to verify the licensee's actions as required by IE Bulletin 79-19 with respect to activities related to the transfer, packaging and shipping of low level
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radioactive waste materials. The inspection involved 16 inspector-hours by one regional based NRC inspector.
Results: Of the area inspected, no items of noncompliance were identified.
(Rev. April 77)
8002280 3Yb Region I Form 12
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DETAILS 1.
Persons Contacted
- Mr. L. B. Russell, Chief Engineer
- Mr. A. J. Kaupa, Radiation Safety and Chemistry Engineer
- Mr. E. T. Riemer, Plant Health Physicist Mr. J. Speciale, Foreman, Radiation Safety Mr. P. Crinigan, Radiation Safety Engineer
- Mr. M. E. Bowman, Supervisor, Quality Assurance Auditing
- denotes those present at t'ie exit interview conducted on December 7,1979.
The inspector also intervitwed other individuals, including plant health physics personnel.
2.
Scope IE Bulletin 79-19, " Packaging of Low Level Radioactive Waste For Transport and Burial," dated August 10, 1979, informed licensee's of several examples of violations that had been noted in the packaging and transport of low level radioactive waste. As a result of these numerous examples, certain actions were required to be taken by the licensee's in al effort to assure that future packaging and transport.of radioactive waste would be in compli-ance with Agreement State, DOT, and NRC reaulatory requirements.
Baltimore Gas and Electrici Company responded to IE Bulletin 79-19 in a letter dated September 28, 1979.
The inspection effort verified the licensee's actions as required by the Bulletin with respect to activities related to the transfer, packaging and transport of low level radioactive waste material.
3.
IE Bulletin 79-19, Action Items To assure the safe transfer, packaging and transport of low level radioactive waste, each licensee is expected to:
a.
Maintain a current set of DOT and NRC regulations concerning the transfer, packaging and transport of low level radioactive waste material.
Finding: Although the facility is in possession of current DOT and NRC regulations, the inspector found that regulatory documents used in the field (from which procedures on radioactive waste handling developed)
were not current in that the NRC regulation 10 CFR 71 which the licensee was utilizing was last revised in August, 197.
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The D0T regulations that the licensee utilized are based on the D0T requirements issued as of October 1,1977, which the licensee keeps updated by incorporating revisions as they are issued by DOT.
Upon notification the licensee initiated imediate action to update 10 CFR 71 and to develop an administrative system to assure that the field set of regulations is kept current.
b.
Maintain a current set of requirements Picense) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low level radioactive waste material for transfer and shipment to the Agreement State licensee.
If a waste collection contractor is used, obtain the appropriate requirements from the contractor.
Finding: The inspector verified that the licensee has on file the most recent Agreement State license (South Carolina Radioactive Material License No. 097, Amendment No. 26, issued October 30,1979).
Additionally, the licensee also has on file the current requirements as specified by the burial site contractor, Chem-Nuclear Systems, Inc.
Designate, in writing, people in your organization who are responsible c.
for the safe transfer, packaging and transport of low level radioactive material.
Finding: The inspector verified that management personnel who are responsible for the packaging and transport of low level radioactive matertal are designatedin writing in the licensee's Quality Assurance document QAP-3.
d.
Provide management-approved, detailed instructions and operating procedures to all personnel involved in the transfer, packaging and transport of low level radioactive material.
Special attention should be given to controls on the chemical and physical form of the low level radioactive material on the containment integrity of the packaging.
Finding: The inspector verified that the licensee does have management-approved procedures addressing the transfer, packaging and transport of low level radioactive material.
The following procedures were reviewed:
CCI 400B, Radiation Safety Manual,Section IV, " Control and
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Accountability of Radioactive Material."
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RCP-3-501, Revision 2, Origin and Depocit'>n of Radioactive
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Material.
RCP-3-502, Revision 4, Low Level Solid Radioactive Waste Control.
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RCP-3-506, Revision 8, Packaging, Labeling and Shipment of Radio-
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active Material.
OI-17A, Solid Waste.
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During the course of this review, the following was observed:
(1)
Procedure RCP-3-506 provided loading specifications for four shipping containers utilized by the license, i.e.:
Model No.
D0T Type (a) HN-200 USA /6574/B ( )
(b) GE-1600 USA /9044/B ( )F (c) HN-100, Series 2 USA /9079/A (d)
HN-100, Series 1 USA /9086/A In reviewing the Certificates of Compliance (C0C) for these containers, the following was observed:
Licensee's Current.
Most Recent Model No.
C0C No.
Revision Revision HN-200 6574
2 GE-1600 9044
2 HN-100, Series 2 9079
3 HN-100, Series 1 9086
2 With the exception of the HN-100, Series 2 container, the licensee's copies of C0C's were outdated by as much as 8 months. However, the inspector did not find evidence of any previous 1979 shipment being made without a valid C0C in effec.
To correct this situation, the licensee immediately acquired current C0C's and initiated action to provide for an administra-tive system to assure that the C0C's were kept current.
(2) Operational Instruction,01-17A, Revision 3, provides instructions transferring expended resin to the Spent Resin Metering Tank for loading into shipping casks.
The procedure specifies a dewatering technique to be employed which t.tilizes a 25 GPM self priming rubber impeller gear pump. The licensee recognizes that though a large portion of liquid is removed by use of this pump, absolute dewatering is not accomplished.
To complete the dewatering process to be in accord with the free standing liquid specifica-tions of the Aareement State License (South Carolina License No.
097, Amendment 26), the licensee augments the 01-17A by an:.ther process which has not been described ii any procedu e.
The technioue involves the positioniig of two or more well points on the bottom of the cask liner pricr to resin load.
These well points are pmped with a low volume of suction pump at intennitent interva'a until no free standing liquid is observed.
Previous testing und experience with this technique indicated ti.at between 80 to 150 gallons of free standing liquid can be extracted after the initial dewatering sequence has been accomplished pursuant to 0I-17A.
Th> inspector indicated tha', prior to any further shipment of dewatered resin, all dewatering techniques must be described in a management-approved procedure in such a way to assure that the licensee does meet the criteria specified by the regulatory requirements.
Upon notification, the licensee initiated action to revise 01-17A to incorporate all of the dewatering techniques utilized in the packaging of spent resin prior to any further shipments.
This item will be reviewed in a subsequent inspection (317/79-22-01 and 318/79-21-01).
(3)
Procedure RCP-3-506 was reviewed; and the following comments were made to the licensee:
(a)
In accordance with 49 CFR 173.393(b) the procedure did not provide for seal devices to indicate illicit packaging openin (b)
In accordance with the COC for HN-100, Series 1 and 2 containers, the procedure did not provide for inspection and use of the VITON 0-ring gasket; nor does the procedure specify the covering of the lifting and shield plug lifting lugs when the package is in transit.
(c) There is no procedure specified for loading the GE-1600 container.
(d) Shoring requirements are not specified for HN-100, Series 1 and 2 containers.
(e) The language used to incorporate the Agreement State License requirements (South Carolina License No. 097) for free standing water is vague and does not provide the necessary specification.
(4) Procedure RCP-3-502 was reviewed and the following cocinents were provided to the licensee:
(a) There is no weight limit specified for the 17H (Specification A) steel drums used for shipping compacted solid radioactive waste.
(b) There is no provision for assuring that a gasket is inserted between the 17H drum body and lid prior to drum closure when the container is used as a Specification A package.
Upon notification, the licensee initiated action to review the specified procedures and to incorporate the required specifications as necessary.
This item will be reviewed in a subsequent inspection (317/79-22-02 and 318/79-21-02).
e.
Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material. Maintain a record of training cates, attende;s, and subject material for future inspections by NRC personnel, f.
Provide training and periodic retraining to those employees who operate the processes which generate waste to assure that the volume of low level radioactive waste is minimized and that such waste is processed into acceptable chemical and physical form for transfer and shipment to a low level radioactive waste burial facilit,
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Finding: The licensee identified four personnel who were directly responsible for activities affecting the transfer, packaging and transport of radioactive material and who were supposively trained in the applicable regulations and procedures relating to this area. On review of the training records for these individuals the following was found:
Individual A Initial Training: June 11, 1974 DOT Regulations Training:
September 28, 1976 Individual B Initial Training:
September 28, 1979 Individual C No record of related training.
Individual D No record of related training.
The licensee representative indicated that the required training had been administered pursuant to the specifications of IE Bulletin 79-19, but was unable to find documentation of such training.
(An interview with Individual B indicated that such training had been administered.)
On December 11, 1979, the Plant Health Physicist informed the inspector by telephone that the training documentation had been recovered and that it was available for inspection and that copies would be sent to the regional office for review and verification.
This item will remain open pending review of the training documentation (317/79-22-03 and 318/79-21-03).
g.
Establish and implement a management-controlled unit audit function of all transfer, packaging and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory requirements.
h.
Perform, within 60 days of the date of this bulletin, a management-controlled audit of your activities associated with the transfer, packaging and transport of low level radioactive waste.
Maintain a record of all audits for future inspections by NRC or D0T inspectors.
(Note:
If you have an established audit function and have performed such an audit of all activities in Items 1-6 within the past six months, this audit requirement is satisfied.)
Finding: The licensee has implemented an audit function to review the area of radioactive material transfer, packaging and transport in accordance with the Quality Assurance Program specified by 10 CFR 50, Appendix B.
The Supervisor, Quality Assurance Audit indicated that
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the audit. prJgren would be reviewed to assure that depth of the performed audits was suf"cient to render evident reliability to this particular area. The inspector indicated that the licensee's quality assurance program as required by 10 CFR 71.51, " Establishment and maintenance of a quality assurance program," would be reviewed in a subsequent inspec-tion to ascertain that all of the elements of the prescribed program are implemented (317/79-22-04 and 318/79-21-04).
The inspector reviewed the licensee's audit of the radioactive waste management activity as required by IE Bulletin 79-19.
The audit #3-28-79, " Audit of QAP-3 Radioactive Waste", was perfomed between September 13 and October 3,1979, and encompassed the areas covered by QAP-3 and the IE Bulletin 79-19. Audit findings were brought to the attention of the Chief Ingineer of the Calvert Cliffs Nuclear Generating Station, as well as the Vice President - Supply, Baltimore Gas and Electric Company. The Radiation Safety and Chemistry Engineer was informed of the findings and responded with the necessary corrective actions.
Followup on these specified corrective actions had not yet been performed by the Quality Assurance Auditing Unit at the time of this inspection but was planned.
No items of noncompliance were identified in this ared.
d.
On Site Observations The inspector observed the preliminary activities preparing a resin liner for loading from the Spent Resin Metering Tank. This activity is described in 0I-17A, " Solid Waste." At the conclusion of this inspection the loading activity had not commenced, therefore, full review of this activity was not performed.
Since there was no other packages on site awaiting shipment, no containers were opened to verify the abser.ce of free standing water.
5.
Exit Interview The inspector met with the licensee representatives (denoted in Detail 1)
at the conclusion of the inspection on December 7, 1979.
The inspector summarized the scope and findings of the inspection as presented in this report.
The licensee made the following commitments:
Prior to any further shipments of radioactive resin, 0I-17A will be
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revised to fully indicate the dewatering technique employe,
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Immediate action will be taken to assure that DOT and NRC regulatory
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requirements are kept current at the field location, i.e., Plant Healtn Physics Office.
Immediate action will be taken to assure that the Certificate of
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Compliance and all documents referenced therein are kept current at the field location, i.e., Plant Health Physics Office.
RCP-3-501, RCP-3-502, and RCP-3-506 would be reviewed to assure that
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they reflect the most recent regulatory requirements and are comoatible with the package requirements specified.