IR 05000334/1993015

Insp Repts 50-334/93-15 & 50-412/93-16 on 930726-30.No Violations Noted.Major Areas Inspected:Transportation of Radioactive Matls,Radwaste Processing,Staffing Levels,Staff Qualifications,Training & Quality Assurance

ML20056D510
Person / Time
Site:	Beaver Valley
Issue date:	08/06/1993
From:	Joseph Nick, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056D508	List: IR 05000334/1993015 ML20056D507
References
50-334-93-15, 50-412-93-16, NUDOCS 9308170020
Download: ML20056D510 (9)

Text

.

i

.

. ,

U.S. NUCLEAR REGULATORY COMMISSION ,

REGION I

t

Repon No /93-15 50-412/93-16 Docket No :

50-412 Licensee: Ducuesne Light Company P.O. Box 4 Shippingoon. Pennsylvania 15077

.

Facility Name: Beaver Valley Power Station Inspection At: Shipnincoort. Pennsyh'ania

{

Inspection Period: July 26 - 30.1993

.

Inspector: O Uk 8/9 . J. Nick, kadiation S'pecialist Date'  :

Facilities Radiation Prot tio Section, '

D' sion of Reactor ty an Safeguards (DRSS) [

Approved by: Od hI ' "

SA L D 3 Wait Pasciak, Chie{ Date  ;

Facilities Radiation \Frotection Section, DRSS Areas Insoected: Transportation of radioactive materials, radwaste processing, staffing levels, ;

staff qualifications, training, quality assurance, radwaste and transportation pmcedure Results: The licensee maintained an effective radwaste ad transponation pmgram with minor weakness noted. Within the scope of this inspection, one non-cited violation was identified involving the improper completion of shipping papers for radioactive materials (See Section 7.0).

,

b i

t 9308170020 930B06 i PDR ADOCK 05000334 G PDR

- ,, ,

,

-

,

-  ;

DETAILS l

!

Persons Contacted [

! Licensee Personnel i

• J. Sieber, Senior Vice Pmsident -f

• D. Spoerry, Vice President - Nuclear Operations  :

• G. Thomas, Vice President - Nuclear Services l

• R. Vento, Manager, Health Physics ,

• W. McIntire, Dimetor, Safety and Environmental Services i

• F. Logar, Director, Site Facilities /Radwaste  !

• D. Girdwood, Dimetor, Radiological Operations Unit 1 l

• E. Cohen, Director, Radiological Operations Unit 2 l

'

• A. Castagnacci, Senior Health Physics Specialist

'F. Lipchick, Senior Licensing Supervisor

• K. Grada, Manager, Quality Services Unit i B. Sepelak, Licensing Engineer [

,

J. Belfiom, Senior Quality Assurance Specialist L. Winters, Operations Supervisor {

. M,. Shaw , Nuclear Training Inr,tmetor  !

l Various other licensee employees were contacted and interviewed during this inspectio , NRC Personnel l

.;

L. Rossbach, Senior Resident Inspector ,

• P. Sena, Resident Inspector {

S. Greenlee, Resident Inspector j

Other  !

i

• R. Barkanic, Pennsylvania DER /BRP

• Denotes those present during the exit meeting i Pumose The purpose of this announced inspection was to assess the licensee's implementation of ;

the radiological controls for radioactive waste processing and tansportation. Program elements myiewed included transportation of radioactive materials, radioactive waste processing, organization and staffing levels, staff qualifications,- training, quality _ ,

assumnce, and radioactive waste processing / transportation pmcedure i

i i

i

i

. . .

.

.

L Facility Tours Radioactive Waste Systems The inspector toured the radioactive waste systems for Unit I and Unit 2. Areas included the radioactive waste processing areas, the operational control panels, the drumming and drum storage areas, the spent fuel pools, and shipping cask and liner preparation areas. All areas were well maintained and exhibited good housekeepin Proper radiological posting and controls existed in most areas. High radiation areas were controlled by a barrier and locked as required by regulations. One minor discrepancy

in the posting of a radiation area was reported to licensee's supervision by the inspecto The discrepancy was corrected immediately and was verified by the inspector the next +

'

da .2 Radioactive Waste Stomge I

'Ihe licensee maintained a separate building, Waste Handling Building (WHB), outside the protected area for future storage of solid and processed radioactive waste. The

'

concrete building was constructed and designed to hold the amount of radioactive waste :

generated in approximately five years of plant operation. The licensee will begin storing .

!

processed radioactive waste in this facility when the disposal site in Barnwell, South Carolina closes in June 1994. The waste will be stored until the Appalachian Compac j site is available. If the regional waste compact's low level radioactive waste disposal site ;

is not available after five to seven years of interim storage, the building could be expanded to hold more low level radioactive waste. The inspector found the building in good condition. Radiation monitors and fire detection systems were in place. The !

facility was recently emptied of all excess items in preparation for use in the middle of year 1994. A few items were still being stored in the waste cubicles. The use of the l building and methods for personnel access control will be reviewed in future inspections when the facility is used to. store radioactive wast .

'

The licensee had expended significant resources to reduce the inventory of radiological materials on the site. Irradiated hardware was removed from the spent fuel pools and .

shipped to the disposal site in South Carolina. Radioactive waste oil was sent to a !

vendor for processing and disposal. The licensee had a small quantity of mixed hazardous waste that had not been shipped, but was stored in a small storage buildin '

Approximately 20 barrels of resin were stored outside the Unit I radioactive waste processing area. The licensee also had 2 Sea /12nd containers for accumulation of dry ;

radioactive' waste from each unit. Barrels containing contaminated protective clothing were stored in various other areas of the sit .

- . ,

.

.

.

l Oreanization and Staffine  !

The radwaste organization had changed since the last inspection. A new Health Physics Manager had been promoted from Director of Radiological Health Services when the pmvious manager 1 tired in January 1993. Instead of filling the open position in !

Radiological Health Services, the organization was restmetured to eliminate the positio l

'

The functions of the Director of Radiological Health Services were divided among two other directors. This change created the Director of Safety and Environmental Services i and the Director of Radiological Engineering and Health Services. These two directors i and the two Directors of Radiological Operations (Units 1 and 2) reported to the Health Physics Manager. The Health Physics Specialists who supported the radioactive waste i~

program were reassigned to the Director of Safety and Environmental Services. The Health Physics Specialist and two technicians were still assigned to support the :

radioactive waste program from the Radiological Operations group. The Senior Health :

Physics Specialist from the Safety and Envimnmental Services group was designated as !

the Radwaste Coordinator. Although the organization stmeture had changed, the  ;

I radioactive waste program operated in a similar manner. The organizational change did not have a significant impact on the radioactive waste program. The licensee had l qualified individuals within the organizatio .0 Trainine f

.

The inspector reviewed the licensee's training records for personnel assigned to .

radioactive waste processing and transportation. The licensee had initial training l programs for health physics, operations, and quality control / quality assurance personnel. [

The initial training was a two day course that covered the regulatory requirements and }

specific instructions based on the licensee's procedures. Annual retraining was required

!

for all personnel involved in the radioactive waste processing and transportation activities. One day of retraining included a review of the regulatory requirements and i the licensee's procedure .

The inspector reviewed the training records for a representative sample of the employees who had performed job functions in the radioactive waste program during the last two years. Training records were kept in good condition and were easy to access. All !

employee's records indicated that the required training was given. Training documents indicated passing scores on examinations given at the end of the training courses. ' Hie training lesson plans for these areas indicated a comprehensive and informative course i content. The training instructor had attended a vendor course in radioactive waste !

management and transportation approximately every two years. This amount of training <

was appropriate considering the material review time required prior to each classroom instructio ;

I b

b

&

_ -_ _ _ _ . _ _ _ . _

. . . . . . -. . . -

k

.

'

,

5 l i

I I

A program improvement was noted by the inspector in the On-The-Job (OJT) trammg  ;

for Health Physics technicians assigned to radioactive waste pmcessing. The initial *

classroom and OJT training were given when a technician was first qualified. The ,

technician was then assigned to various positions within the Heahh Physics organizatio j Two technicians were normally assigned to the radioactive waste program for a period !

of two years each. Since there were approximately 55 health physics technicians, there l could be a significant time period between initial qualification and assignment to !

mdioactive waste processing. Therefore, the licensee had developed a refresher to the t

,

OJT training. The licensee planned to give refresher classroom and OJT training when !

the technicians were assigned to rotate into the radioactive waste program. This was a -

considerable impmvement over the past practice where only refresher classroom training ;

was given to techmcians upon assignment to the progra ;

The inspector also reviewed the licensee response to NRC Information Notice No. 92-72, !

" Employee Training and Shipper Registration Requirements for Transponing Radioactive Materials." The licensee stated in their response that the requirements for training and ;

periodic refresher training for all individuals involved in the transport of hazardous !

materials were accomplished by the trainirig specified in the previous paragraph. In addition, hazardous material training is provided in general employee training and

,

hazardous communications trainin l Two items related to training were identified in an earlier inspection (NRC Inspection Repon Nos. 50-334/91-13; 50-412/91-13). Seme Quality Control (QC) personnel involved with shipments of radioactive material had not received periodic retraining for l over three years. The licensee had committed to develop a one day annual refresher j training for QC inspectors involved in radioactive material shipments. As stated above, l the licensee's records showed that the training had been given to QC personnel on an j annual basis. The second item involved communications between the training depanment :

4'

and the individuals responsible for the radioactive waste program. A review oflesson )

plans had indicated that the training department was not informed of program or process I changes. Since this report, the licensee has held quanerly meetings with the Health j

,

Physics Department to discuss les^.on plan content. Additionally, the Radwaste  !

Coordinator routinely sent an informational copy of memorandum, inspection reports, l

audits, or industry event updates to the training department instmetor. The improved )

communications had resulted in accurate and current information in the lesson plans for !

radioactive waste program trainin i

.

l

_. ___ __ _ __ _ _ . __ _ ,

- . . - _ - - _ . .- - .- . . . -

,

O'

l

'

6 i l Radioactive Waste Processing j

The licensee no longer performed any radioactive waste processing on site with the exception of dewatering of some materials. Liquids were pmcessed through filters and ;

demineralizer beds. The waste evaporators and cement solidification systems were no !

longer used with the exceptions of a metered pump that was used to slurry waste into !

other containers. Resins and filters were placed in High Integrity Containers (HICs) and j shipped to the low level radioactive waste disposal site. Solid radioactive waste, l contaminated components, and Dry Active Waste (DAW) were sent to processors for l decontamination or compaction. Oil wastes were sent to a vendor for burning or other j disposa Twelve main waste streams were monitomd by the licensee including various spent j resins, DAW, various filters, and other radwaste. The licensee evaluated scaling factors !

annually, or less frequently when a shipment contained waste from a particular waste ;

stream, by sending samples off-site for laboratory analysis. The scaling factors were ,

used to estimate the activity of radionuclides that were hard to measure when the waste !

streams were analyzed in the licensee's laboratories. The licensee also sent a split l sample to another independent laboratory to verify the results of the primary laboratory j once every year. The last split samples wem sent in 199 ;

The licensee used their own computer software to assist in classification of waste and i preparation for shipment. Classification and shipping calculations wem verified by the !

inspector on a random sample of some shipping records. No deficiencies were identifie l l

t The inspector myiewed the licensee's msponse to NRC Information Notice 92-62,  !

" Emergency Response Information requirements for Radioactive Material Shipments." }

The licensee reviewed and modified procedures to ensure that necessary information is t

!

,

readily available to emergency responders. A printed envelope was given to the

operations shift supervisor when a shipment left the licensee's site. The envelope ;

contained a copy of the shipping paperwork and had the emergency response guides ;

printed on the outside of the envelope. The emergency response guides contained the l information that would be mquired by an emergency responder at the scene of an  !

accident involving the radioactive material shipment. The shipping paperwork contained dose rate surveys and isotopic conten i i

There were no radioactive waste processing or radioactive material shipment activities :

completed during the period of this inspection; therefore, the emergency information ,

provided to accident responders could not be teste i

!

s

>

b i'

)

i

i

!

= i l

i

.

7 l i

! Records

.

The licensee maintained files on approximately 112 radioactive material shipments in ;

1992. As of the date of this inspection, there were appmximately 142 radioactive ,

material shipments in 1993. A representative sample of files was reviewed for i transportation regulatory compliance. The shipments consisted of material prepared for burial at the low level radioactive waste burial site in Barnwell, South Carolina and ;

radioactive material sent to various waste processors. Two shipments in 1993 were :

placed in High Integrity Containers (HICs) in preparation for direct burial. The remaining shipments were sent to vendors for compaction, incineration, or other processin l The shipment records were well organized, completed and reviewed by qualified l

individuals. Certificates of Compliance were filed for all shipping containers. The licensee verified that a copy of the NRC license for radioactive materials and the latest amendments were on file before the shipment was sent to a facility. The computer j program for classification and shipping was used correctly and all supporting  ;

documentation was properly maintaine l

!

!

One record of a radioactive material shipment that contained fissile materials did not include the fissile status on the shipping papenvork. Shipment RSR-B-1728 was sent to ;

the low level radioactive waste disposal site in Barnwell, South Carolina on December !

28, 1992. The amount of fissile material was under one gram, so the licensee should i have included a " Fissile Exempt" statement on the shipping paperwork. Additionally, the licensee identified the problem in an incident report after notification from the shipper j

'

of an apparent violation from the Department of Transportation due to the shipper's acceptance of the improperly completed shipping papers. The licensee identified several l other occurrences of the missing fissile status on paperwork for other shipments. Timely .;

and adequate corrective actions were implemented to ensure that the mistake did not j occur again. The corrective actions included cotmseling of the individuals involved, !

development of a procedure for the calculation of exempt fissile quantities, revising the l existing procedural requirement for fissile status to clarify the regulatory requirement, ;

and revising the training program. This is an apparent violation of 10 CFR 71.5 which l states that licensees who transport radioactive material shall comply with the applicable Department of Transportation regulations. 49 CFR 172.203 states that the description :

for a shipment of radioactive material containing fissile materials must contain the words )

" Fissile Exempt" if the package contains an exempted quantity. Since the exempt '

quantity is 15 grams and the quantity shipped by the licensee would probably never l exceed one gram, the safety significance of this violation is minor. Because this is an ;

Severity I.evel V violation for which the licensee took prompt corrective action and the l efforts met the criteria specified in Section VII.B of the Enforcement Policy (10 CFR 2 l Appendix C), this violation will not be cite I l

l

)

l l

___ _ ._ __ ____ _

'

.

!

t

!

!

8.0 Ouality Assurance The main components used for the assurance of quality in radioactive waste processing and transportation included periodic surveillances conducted by the licensee's Quality ,

Services group and procedural hold points for quality control inspections. The Health l Physics Department also performed surveillances. The licensee had committed to an audit of the program every 18 months. The inspector reviewed the results of the ;

surveillances and the last audi The last audit by the licensee's Quality Assurance group was conducted in April 199 The areas reviewed in the audit included observation and evaluation of radioactive waste i

!

processing, handling, packaging and shipping activities; interviews with personnel; review of associated documentation and procedures; and inspection of radioactive waste ;

storage and processing facilities. Although the audit was comprehensive and detailed, ;

it was performed by the licensee's Quality Services staff with no assistance from a j technical expert. A licensee representative stated that the next audit was planned for September 1993 and would include a technical expert fmm outside the licensee's !

organization as an audit gmup member. Two observations were documented in the audit

'

report. The first observation concerned the inadequate control of the software used for radioactive waste calculation The second observation noted procedure and documentation deficiencies associated with radioactive waste processing and shippin t Corrective actions for the deficiencies were completed during the audi ;

i Additionally, the Quality Services group had conducted a surveillance of 16 radioactive material shipments and radioactive waste processing activities in 1992. As of the date :

of this inspection, the Quality Services group had conducted a surveillance of 6 activities for 1993. The inspector noted that the number of surveillance activities had decreased .

in 1993. Various reasons were given by licensee representatives, including the statement !

that the decrease was intentional due to the recent good performance in these area l According to surveillance reports, the activities were determined to be satisfactory with l only minor concerns that were immediately corrected by the licensee's staf l

!

9.0 Proceduin i

The pmcedures for the radioactive waste program were reviewed by the inspector. The procedures were generally well written with detailed instructions in most areas. One minor deficiency was noted in the procedure for estimation of the curie content in radioactive material containers (Chapter 3, RadCon Pmeedure 3.40). The pmcedure stated that the surface of the container was scanned for the highest dose rate readin ,

From the side of the container with the highest dose rate, the dose rate should have been obtained at the midpoint of the container at the appropriate distance away fmm the containcr. For the records reviewed by the inspector, the licensee had not used the dose i

l

!

- _ . - - . . _ . --

.

.- _

!

.

.

rate at the midpoint of the container for calculation of curie content. Instead, the licensee had used both the average dose rate and the highest dose rate on different ,

occasions for calculation of the curie content. Although the dose rates used by the - )

licensee were conservatively higher than the procedurally required dose rates, the procedure did not provide good guidance in this area. The licensee's Radwaste Coordinator agreed that the procedure should be reviewed for possible revision to !

_!

provide better guidanc The Process Control Program (PCP) for both units was reviewed by the inspecto ;

Although the PCP did not provide detailed parameters for processing radioactive waste, ;

the document was adequate for describing the dewatering and vendor processing currently *

used by the license .0 Exit Meeting A meeting was held with licensee representatives at the end of the inspection period on -

July 30,1993. The purpose and scope of the inspection wem myiewed and the findings ,

of the inspection were discussed. The licensee acknowledged the inspection finding [

,

.

,

b

>

>