IR 05000317/1987015

Insp Repts 50-317/87-15 & 50-318/87-17 on 870713-17.No Violations Noted.Major Areas Inspected:Solid Radwaste Processing,Preparation,Packaging & Shipping Program, Including Organization,Procedures & Radiochemistry

ML20237H797
Person / Time
Site:	Calvert Cliffs
Issue date:	08/05/1987
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237H791	List: IR 05000317/1987015 ML20237H788
References
50-317-87-15, 50-318-87-17, NUDOCS 8708250155
Download: ML20237H797 (8)

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OFFICIAL RECORD COPY U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Combined Report Nos. 50-317/87-15 50-318/87-17 Docket No and 50-318 License No DPR-53 Priority Category , C DPR-69 Licensee: Calvert Cliffs Nuclear Power Plant ' Units 1 and 2 P.O. Box 1475 Baltimore, Maryland Facility Name: Calvert Cliffs Nuclear Power Plant - Units 1 and 2 I

Inspection At: Lusby, Maryland Inspection Conducted: July 13-17, 1987 l Inspector: . EL S[4!97 H. Bic% house, Radiation Specialist date (

Approved by: . M 8!87 d6te'

W. J. Pgy' cia k , P T Effluep'sRadiationProtectionSection Inspection Summary: Combined Inspection on July 13-17, 1987 (Combined Report No. 50-317/87-15 and 50-318/87-17)

Areas Inspected: Routine, unannounced safety inspection of the solid radioac-  ;

tive waste (radwaste) processing, preparation, packaging and shipping program including: previously identified items, organization, procedures, indoctrin-ation and training, quality assurance / quality control, radiochemistry, low-level radwaste storage facility, processing / storage of solid radwaste, radwaste generator requirements and radwaste shipping requirement Results: No violations were noted. The licensee appeared to be implementing an effective program in the areas examine ;

B700250155 870818

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DETAILS Persons Contacted 1.1 Licensee Personnel

• A. Anuje, Supervfiior, Quality Audits Unit

• R. Bodin, Supervisor, Quality Control-Operations M. Bowman, General Supervisor-Fuel Management W. Cartwright, Engineer-chemistry P. File, Senior Engineer-Fuel Management

• L. Lauagoite, Licensing Engineer J. Lemons, Manager-Nuclear Operations

• N. Millis, General Supervisor-Radiation Safety B. Radford, Principal Technician-Chemistry

• E. Roach, Auditor-Quality Assurance P. Robinson, Inspector-Quality Control Operations C. Struhle, Inspector-Quality Control Operations A. Vogel, Supervisor-Technical Training

• B. Watson, Assistant General Supervisor-Radiation Safety Other licensee personnel were contacted or in'terviewed during the course of the inspectio .2 NRC PERSONNEL

• T. Foley, Senior Resident Inspector D. Trimble Resident Inspector

• Attended the exit interview on July 17, 1987  ;

2. 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 October 25, 1985 through July 17, 1987. During that period, the licensee averaged one radwaste shipment per mont In 1986, the licensee shipped 8,069 cubic feet of solid radwaste for disposal. For 1987 through July 17, 1987, the licensee had shipped 3,547 cubic feet (with approximately 2,500 additional cubic feet on hand being readied for shipment). A sample of ten shipments was selected (representing Type A. Low Specific Activity and Type B shipments under iltle 49 and classes A, B and C under 10 CFR 61) and 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 Specifications. In addition, a review of the licensee's low-level radwaste processing and storage facility, (i.e. the Materials Processing Facility or "MPF") and the Units, radiochemistry was complete . Previously Identified Item _s 3.1 (closed) Followup Item (50-318/85-30-03) Audit Criterion IV fcr packages

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Licensee's quality assurance Audit No. 86-23 (July 23, 1986)

reviewed procurement of shipping containers. The audit addressed 10 CFR 50, Apnendix B, Criterion IV as it related to shipping containers. This item is close .2 (closed) Followup Item (50-318/86-05-02) Procedure for Standup Whole Body Counter Radiation Safety Procedure (RSP) 3-304, " Chest / Abdomen Measurement for Internal Radioactive Contamination for Screening, or Quantitative Purposes," Revision 2 (July 24, 1986) described the operation, data processing and calibration of the standup whole body counter (i.e. " Quantum-8 System"). Other procedures, (e.g. RSP 3-301 and 3-302) referenced use of this whole body counting system as a screening method. This item is close . Organization The organizational structure of the licensee's Materials Processing Unit was reviewed. The Materials Frocessing Unit has responsibility for transferring solid radwaste from the protected area to the Materials Processing Facility (MPF) processing and preparing solid radwastes in the ing those radwastes to the burial sites. The MPF and Processing Materials packaging Unit and shipp(in the Radiation Safety Section) is comprised of four Radiation Safety Technicians, eight Material Processing Assistants and a clerk reporting to the Supervisor-Materials Processing. The position of Supervisor-Materials Processing was open during the inspectio Direction to the unit was being provided by the Assistant General Super-visor-Radiation Safety. The responsibilities of the Materials Processing Unit were clearly defined in Calvert Cliffs Instruction (CCI) 803A,

" Radioactive Materials Management," and no concerns related to organization were note . Procedures The licensee's procedures for processing, preparation, packaging and shipping solid radwaste materials were reviewed relative to criteria provided in 10 CFR 10.311, 10 CFR 71.5, 10 CFR 71.12 and the licensee's Technical Specifications. The following procedures were reviewed, discussed with the licensee and checked for implementation:

RSP 2-201, " Receipt and Tagging of Radioactive Material and Transport Packages";

• RSP 2-202, " Low-Level Solid Radioactive Waste Control";

RSP 2-204, " Packaging, Labeling and Shipment of Radioactive Materials";

RSP 2-208, "HN-100 Series 1, 2 and 5 Cask Handling Procedure";

RSP 2-215. " Radioactive Oil, Grease and Oily Waste Absorption";

RSP 2-217. "CNSI High Integrity Container Handling and Resin Loading Procedure";

RSP 2-218, "CNSI 14-195 H Cask Handling Procedure";

• RSP 2-225. "011 Filtration";

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RSP 2-228 " Acid and Oil Solidification";

RSP 2-229, "CNS 8-120 A Cask Handling Procedure";

RSP 2-230, " Filter Encapsulation" and

• Chemistry Procedure (CP) 228, " Solid Waste Scaling Surveillance Procedure."

Within the scope of this review, no violations were noted. The licensee's procedures appeared to be technically correct and had been appropriately implemented for the ten radwaste shipments reviewe . 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 Radiation Safety, Quality Control and Quality Assurance personnel was reviewed with the Superivsor-

-Technical Training, discussed with selected individuals in the groups trained and the training records were examined. In May 1986, the licensee provided two sessions of regulatory awareness training to approximately forty individual The training was provided by ChemNuclear Systems, Inc. onsite on May 12-15 and 14-17, 198 Within the scope of this review, no deviations from commitments were note . _ quality Assurance / Quality Control Under Technical Specification 6.16, the licensee is required to operate the solid radwaste treatment system in accordance with a Process Control Program (PCP) to process wet radwaste materials to meet shipping and disposal requirements. Specific quality control requirements are also 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 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 IE Information Notice No. 84-50. Guidance regarding waste classification was provided in the Branch Technical Position in Classification and NRC-IE Information Notice No. 86-20. Guidance on waste form was provided in the Branch Technical Position on Waste Form and NRC-IE Information Notice No. 87-07 reminded licensees of their responsibilities to ensure process control for vendor-supplied solidification services. The application of the licensee's quality assurance / quality control program to the licensee's responsibilities as a radwaste generator and shipper was reviewed.

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7.1 Waste Generator Quality Control / Process Control Program Licensee's procedures were reviewed to determine if appropriate quality contrcl checks were included to ensure proper classification of radwaste shipments under 10 CFR 61.55 and proper radwaste form under 10 CFR 61.56. For the ten shipments reviewed, implementation of procedural holdpoints and other quality control verification was reviewed and discussed with quality control personnel. Licensee Audit No. 86-29 " Solid Radioactive Waste," (July 1. - September 19, 1986) was reviewed to determine its inclusion of attributes related to 10 CFR 61.55-56 compliance, licensee management review of the audit and resolution of findings and recommendations. The inspector noted that appropriate inspection hold points were provided in the procedures and had been implemented for the shipments reviewed by quality control personnel trained and qualified under the licensee's training program. Audf* No. 86-29 adequately covered attributes of

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10 CFR 61.55-56 (including surveillance of ongoing activities) and had received appropriate licensee management revitw and resolution of finding Within the scope of this review, no violations were noted. The licensee appeared to be implementing an effective quality control program under 10 CFR 20.31 .2 Radwaste Shipper Ouality Control / Quality Assurance Licensee procedures were reviewed to determine quality control attributes verified in receipt inspections of transport package Implementation of those procedures for general licensed transport packages (under 10 CFR 71.12) represented in the ten shipments reviewed was verified by examination of pertinent shipping record (See related item Detail 3.1). Procedures were also reviewed to verify quality control inspection of applicable items of the pack-aging's Certificate of Compliance prior to shipment departure and to determine if those inspections were completed for the shipments reviewed. Quality Assurance Audit No. 86-29 was reviewed for inclusion of attributes needed to ensure compliance with 10 CFR 7 Within the scope of this review, no violations were note . Radiochemistry The inspector briefly reviewed licensee fuel performance data, ion-exchange resin characteristics and " CRUD" behavior with the licensee's Chemistry and Fuel Management representatives to determine the general adequacy of the licensee's sampling and vendor analysis program for difficult-to-identify radionuclides. The licensee has experienced fuel failures initiated by incore debris-induced cladding, thinning and secondary hydriding once cladding is initially breached. The most recent examinations of the two units' fuel is summarized in the following teble:

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'= 6 Unit Fuel . Cycle No. Failed Pins Fuel Pellet Loss 1 8 3 yes 2' 5 4 yes 2 7 6 yes Although the. licensee has experienced less than 0.1% fuel pin failure rates, the failed fuel pin damage.has been significant allowing fuel pellet water interaction and pellet fragment escape. Radiochemical data reflected Iodine ratios clearly indicative.of fuel failure and initial assessments based on that data indicated a significantly larger number of failed pins. However, the' assessments were complicated by the unusual degree of individual fuel pin failure, i.e. extensive cracking in the failed pins.. From this review of fuel performance data, the inspector concluded that Chemical and Volume Control System (CVCS) filters and primary resins were likely to contain significant transuranic activit The licensee does not use high colloidal removal. ion-exchange resins in the primary coolant system. Resins with high cesium retention characteristics aren't used. Mixedactivationproduct,(" CRUD"), bursts appeared to be controlled during operation and shutdow . Low-Level Radwaste Facility The. licensee's Materials Processing Facility or MPF was designed and built to provide on-site storage of five years of dry active waste (DAW),

decontamination of radwaste materials, clothing, respirators, tools, et and capability to receive, sort, shred, compact, package and ship DA The design, construction and operation of the MPF were reviewed against 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 Generic letter 81-38); and

- NRC-NRR Generic Letter 81-38 and its enclosure entitled

" Radiological Safety Guidance For Onsite Contingency Storage Capacity."

Design criteria related to the MPF was reviewed and discussed with the licensee and the MPF was toured to detemine the licensee's compliance with the criteria and guidance above. The safety analysis report was reviewed to determine the licensee's assessment of projected off-site doses from normal operations and postulated accidents. Flow patterns for radwaste processing including shredding, compacting, packaging, storage and'

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7-shipping activities were reviewed. The inspector noted that the MPF had been reviewed and approved (under 10 CFR 50.59) initially during Plant Operations and Safety Review Committee (POSRC) Meeting No.83-106. The POSRC had also reviewed and approved procedures and tracked improvement items until their completion. During POSRC Meeting No.83-106, the licensee had concluded that the MPF 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 Specification Within the scope of this review, no violations were note . Solid Radwaste Processing / Storage The inspector reviewed the licensee's solid radwaste processing activities including resin dewatering, vendor-supplied solidification of CVCS filters and contaminated oil absorption. Segregation of hazardous wastes, (i.e. NRC-IE Information Notice No. 87-03) was also reviewe Temporary onsite storage of solid radwaste was also reviewed (see Detail 9). Licensee reports summarizing solid radwaste operations were reviewed for obvious mistakes, anomalous measurements of radioactivity and omission Within the scope of this review, no violations or concerns were identifie . Radwaste Generator Requirements The inspector selected a sample of ten shipments representing dewatered

. resins, solidified filters, DAW and absorbed oil and reviewed each against 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 210.311(d)(a) and 10 CFR 61.55;

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Waste Form and Characterization under 10 CFR 20.311 (c)(a) and 10 CFR 61.56; l

- 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 South Carolina and Washington 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, etc.) was also reviewed for each shipment relative to guidance provided in the Branch Technical Positio Within the scope of this review, no violations were note .. - . . .

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1 Radwaste Shipping Requirements The ten shipments were reviewed relative to criteria contained in 10 CFR l 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 ten 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 interviews of Materials Processing Unit and Quality Control personnel and review of documents and radioactive shipping record Within'the scope of this review, no violations were identifie .2 Preparation of Packages for Shi3 ment The licensee's preparation of tie packages for shipment was reviewed relative to the requirements of 49 CFR 172 and 173, 10 CFR 71.87 and the~ licensee's procedures. Performance relative to the criteria was determined by discussions with licensee personnel and examination of procedures, radioactive shipping records and other document Within the scope of this review, no violations were note .3 Delivery of Packages to Carriers Tne delivery of packages to carriers was reviewed for compliance with placarding, shipping nanifests and public hig(hway shippingrequirem (vi). The licensee's performance relative to these criteria was determined by review of shipping records and discussion with cogni-

,' zant licensee personne Within the scope of this review, no violations were identifie .4 Transportation Incidents '

The licensee stated that no shipping problems had been noted and no violations or warnings had been received from the State Regulatory agencies regarding their shipments during the period reviewe . Exit Interview The inspector met with the licensee's representatives (denoted in Detail 1) at the conclusion of the inspection on July 17, 1987. The inspector summarized the scope and findings of the inspection as described in this  !

repor At no time during this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this repor l