IR 05000320/1988007

Insp Rept 50-320/88-07 on 880502-06.Violations Noted.Major Areas Inspected:Licensee Solid Radwaste & Transportation Program,Including Mgt Control,Shipments of Radioactive Matls,Training,Procedures & QC

ML20155K555
Person / Time
Site:	Three Mile Island
Issue date:	06/13/1988
From:	Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155K542	List: IR 05000320/1988007 ML20155K539 ML20155K549
References
50-320-88-07, 50-320-88-7, IEB-79-19, IEIN-87-007, IEIN-87-7, NUDOCS 8806210282
Download: ML20155K555 (7)

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k U.S. NUCLEAR REGULATORY COMMISSION REGION 1

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Report N /88-07, Docket N License N OPR-73 Category C Licensee: GPU Nuclear Corporatio_n P.O. Box 480 Middletown, PA 17057 Facility Name: Three Mile Island Nuclear Station Inspection At: Middletown, PA Inspection Conducted: May 2-6, 1988 Inspectors: -

h Ba r . avids , adiation Specialist 'ddte Approved by: [

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14 K Chief, Effluents Radiation

)) S Prote ion Section, FRSSB, DRSS Aate/

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Inspection Summary: Inspection on May 2-6, 1988 (Inspection Report No. 50-320/88-07)

Areas Inspected: Routine announced inspection of the licensee's solid rad-waste and transportation program including: management control, shipments of radioactive materials, training, procedures, package selection and quality contro Results: Two violations of NRC requirements were identified; failure to i account for the total activity in one shipment and failure to include the  ;

radioactivity in the waste drum on shipping papers. These two violations have '

been categorized in the aggregate as one Severity Level IV violatio '

8806210282 880614 PDR ADOCK 05000320 g DCD .

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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewe .1 Licensee Personnel

• E. Schrull, TMI-2 Licensing

• S. Williams, TMI-1 Rad. Engineering

• L. Kramer, TMI-1 Chemistry

• Wells, TMI-2 Licensing

• Sieglitz, TMI-2 Mgr., Waste Management

• Mehler,TMI-1 Radwaste Ops. Manager

• Hukill, TMI-1 Director

• Smythe, TMI-1 Licensing Manager 1.2 NRC

• T. Moslak, SRI (Acting)

1.3 Pennsylvania Bureau of Radiation Protectio _n_

• Singh, Nuclear Engineer

• Denotes those individuals who attended the exit meeting on May 6, 198 .0 Management Controls 2.1 Organization The organizational relationship and structure of the licensee's management control of solid radwaste processing, preparation, packaging and shipping activitier were reviewed. Oversight of contractor activities (NRC IE Information Notice 87-07) was also reviewe The Unit 2 Recovery Engineering and Radwaste Operations groups have responsibilitier for processing resins (505 and EPICOR-II) and mechanical filters. Radiological Engineering personnel assigned to Unit 2 provide calculations to support radionuclide activities and classification under 10 CFR 61.5 Gas and heat generation rates, LSA, Type "A" or "B" determinations, preparation of radwaste manifest and shipping records and packaging are made by the Waste Disposal Group. Quality assurance and quality control personnel provide receipt inspection of packages, vehicle inspections, monitoring of radwaste preparation, surveillances and inspections of shipping operations and audit Within the scope of this review, no concerns were note , _ _ .. --

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, 3 l 2.2 Procedures The licensee's procedures for processing, preparation, packaging and shipping solid radwaste materials were reviewed relative to criteria in 10 CFR 20.311, 10 CFR 71.5, 10 CFR 71.12 and Agreement State Burial Site license Seven procedures were reviewed for adequacy and checked for implementation for six shipments that were reviewe Within the scope of this review, no violations were note .3 Indoctrination and Training The licensee's indoctrination and training program was reviewed relative to commitments in the licensee's response to NRC IE Bulletin 79-19. Training provided to six individuals with varying responsibilities for the six shipments were briefly reviewe Within the scope of this review, no deviations were noted. Biennial training and retraining of supervisory personnel was completed as require . Quality Assurance (QA)/ Quality Control (QC)

Specific quality control requirements are mandated by 10 CFR 20.311 to assure compliance with 10 CFR 61.55 and 10 CFR 61.5 The establishment of a Quality Assurance program of the packaging arid transportation of radioactive m terials is required by 10 CFR 71, Subpart 4. A Commission approved Quaiit.y Assurance program which satisfies the criteria of 10 CFR 50, Appendix C, quality assurance program 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 etivities. The application of the licensee's quality assurance / quality control program to the licensee's responsibilities as a solid radwaste generator and shipper at Unit 2 was reviewe .1 Waste Generator QC/ Process Cor. trol Program Process control procedures for dewatering of SOS and EPICOR-II resins were reviewed to determine verification of proper radwaste form under 10 CFR 61.56. Both radwaste operations supervisory and quality assurance personnel verify suitable waste form Calculations for determining waste classification under 10 CFR 61.55 were peer reviewed within the Radiological Engineering Group and checked by the Waste Disposal Group. The calculations are also evaluated on a sampling basis during quality assurance audits. QA Audit Report 5 TMI-87-05, "Radwaste Management Program," was

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reviewed relative to inclusion of 10 CFR 61.55-56 attributes and licensee management review of tnat audit. Findings regarding program improvement in training were completed in January 198 Within the scope of this review, no violations were foun .2 Radioactive Materials Shipper 0C/0A-Under the licensee's Operational Quality Assurance Plan (0QAP), the licensee had delineated each section of 10 CFR 71, Subpart H and its

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corresponding section.in the OQAP. QA Audit Report S-TMI-87-05 reviewed each applicaule section of the OQAP from QC receipt inspection to final QC inspection and monitoring activitie For the six shipments reviewed, the inspector verified that the licer.see had inspected items of the package Certificates of Compliance.(C0C),

inspected and controlled liners and high integrity containers (HICs),

molitared activities throughout preparation, packaging and shipping activities; and implemented the 0QA Witnin the scope of this review, no violations were note The QA/QC program was effectively implemente . Radsaste Generator Reouirements

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- 4.1 The inspector reviewed the six shipments against each of the followir:g radwaste generator requirements:

Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b' and (c);

Waste Classification under 10 CFR 20.311(d)(3) and 10 CFR 61 44;

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 bases for determining waste class through sampling and analyses, computer codes, dose to curie conversions was reviewed and discussed with Radiological Engineering staf Within the scope of this review the following items cere noted:

• 10 CFR 20.311(b) requires, in part, that the manifest ;

accompanying radioactive waste shipments indicate as completely I as practicable the raIonuclide identity and quantity and the 1 total radioactivity in the shipmen l

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10 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly describe Contrary to these requirements, the manifest accompanying licensee shipment No. 88-025-11 (Manifest No. 103799) did not identify the existence and quantity of radioactive wastes in drum number 155; instead, the manifest identified drum number 159 which was r t in the shipment' .

As a result, the total activity was in erro Furi .er, the certification which 6ccompanied the ma' 'fest was also in erro Failure to account for the activity in the drum which was shipped and the. total activity in the shipment constitute a violation of 10 CFR 20.311(b). Certification that shipment number 88-025-11 was properly described when it was not constitutes a violation of 10 CFR 20,311(c). The licensee's immediate corrective action upon adv 9 9 from the State of Washington was to immediately forward the proper manifest information for drum number 155 and counseling of waste dispcsal group personnel regarding taking responsibilities for their action Further, an administrative form was developed which requires that material handlers sign a log for each package placed on a shipment. These actions appeared to sufficient to prevent recurrence of this even A similar manifest error was recently reported to the State of Washington

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regarding an error in the total strontium-90 activity reported in shipment No. 85-111-11 (manifest No. 74102). The strontium activity on the manifest was given as 236.96 curies vice 472.04 curie This change did not affect waste classificatior, or transportation requirements. The NRC took-enforce-ment action against the licensee regarding the Sr-93 error (i.e. Inspec-tion Report 320/85-15) for three barrels that were misclassified. This resulted because of a failure to communicate the error to the Waste Dis-posal Gro;p. The licensee identified violation noted in the above para- ,

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graph is of the same type previously cited and could not have been pre-vented by the corrective actions. Although the Sr-90 activity was doubled the amount reported, the safety significence'is minimal as there was no misclassificatio ,

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4.2 Procurement and Selection of Package l l

The licensee's selection of packages for the thirteen shipments was reviewed relative to requirements in 49 0FR 173 and 10 CFR 71.12, ,

interviews with Waste Disposal and QC personnfl, and review of '

documents, procedures, and shipping record Within the scope of this review, no violations were foun I 4.3 Preparation of Packages for Shipment

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The licensee's preparation of >ckages for shipment, pursuant to 1 the requirements of 49 CFR 172 and 173 and 10 CFR 71.87 was reviewe I

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The licensee's performance relative to these criteria was determined by interviews with the Waste Disposal Group and review of procedures, shipping records and other document ,

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Within the scope of this review, no violations were note .4 Delivery of Packaoes to Carriers  !

The licensee's delivery of packages to carriers was reviewed against criteria in:

• 10 CFR 71.5(a)(1)(iii), "Placarding;" l

+ 10 CFR 71.5(a)(1)(vi), "Shipping Manifests;"

• 10 CFR 71.5(a)(1)(iv), "Public Highway-49CFR177;" and

• Technical Specification and procedural requirement The licensee's performance relative to these was evaluated by review ,

of shipping records and discussions with licensee personnel, s Within the scope of this review, the following violation was noted:

• 10 CFR 71.Ela)(1)(vi) requires preparation of shipping papers in accordance with 49 CFR 172, Subpart CFR 172.203(d)(iii) requires the activity of each package in the shipment be included in the shipping paper !

Contrary to these requirements, the licensee did not include the activity contained in drum number 155 in the shipping )

pape s associated with shipment number 88-025-II. Failure to

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irclude the activity of drum no.155 in the shipping papers  !

constitutes a violation of 10 CFR 71.5(a)(1)(vi). As noted in section 4.1, the licensee's immediate currective a'ctions appeared to be sufficient to prevent recurrenc .5 Shipment Number 88-025-II, February 19, 1988 l l

Shipment number 88-025-II was sent from the licensee's facility to ,

U.S. Ecology's burial site on February 19, 1988. On February 23, '

1988, the licensee was contacted by U.S. Ecology and advised that container number 159 described on Radioactive Shipment Report (RSR)

number 103799 was not shipped; container number 155 was shipped but not on the RSR. The licensee's immediate response was to transmit by facsimile a copy of the RSR page corresponding to container 155 and subsequently in writing, counsel all the personnel in the Waste Handling Group whether involved in this shipment or not, and issue a form to require signatures attesting the individual who loaded the ftem on a shipment as responsible for its accuracy and the corresponding inclusion of the item on shipping paperwork. These corrective actions appeared to be adequate to prevent recurrenc !

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As a result of this incident, the NRC Resident Inspector was notified. The radiological consequence of the error of loading the wrong item was determined to be minimal because the activity in drum number 155 was 4.7 millicuries vs. 83 in drum number 159. Dose rates for drum number 155 were 12 mR/hr contact and 0.6 mR/hr at one meter vs. 40 mR/hr contact and 3 mR/hr at one meter for drum number 159. Consequently, the carrier or recipient would have been expected to exercise adequate controls on the shipment; no greater potential for personnel exposure or contamination, or improper transfer of materials was expected; and the licensee made timely notification of the incident and its potential violation of NRC requirement . Exit Interview The inspector met with licensee representatives (noted in Section 1.0) at the conclusion of the inspection on May 6, 1988. The inspector summarized the scope of the inspection and findings as described in the inspection repor At no time during this inspection was written material provided to the licensee by the inspecto .

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