IR 05000338/1989019

Insp Repts 50-338/89-19 & 50-339/89-19 on 890605-08.Major Areas Inspected:Solid Wastes,Transportation of Radioactive Matls & Radwaste & Followup on previously-identified Insp Findings

ML20246K331
Person / Time
Site:	North Anna
Issue date:	06/30/1989
From:	Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246K309	List: IR 05000338/1989019 ML20246K303
References
50-338-89-19, 50-339-89-19, NUDOCS 8907180139
Download: ML20246K331 (8)

Text

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Do ' NUCLEAR REGULATORY COMMISSION

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g~ s j~ 101 MARIETTA STREET, .* *  : ATLANTA, GEORGIA 30323.

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JUL 0 7 Igg-Report Nos.:' '50-338/89-19 and 50-339/89-19-

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Licensee: IVirgthcla. Electric and' Power Company

. Glen? Allen, VA 23060 Docket Nos.: 50-338 and 50-339 License.Nos.: HPF-4 and NPF-7, Facility'Name: North Anna 1 and 2 Inspection Conducte June 5-8, 1989

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Inspectgr:  ;

'W p W. B,/Gloersen Da'te Signed Accompanying Personnel: A. W. Gre11a ( Office of Nuclear Materials Safety and Safeguards)

C. J. Pecover (Department of Transport, United in m)

Approved by:- f*

J. W. Potter, Chief D6te' Signed-Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was in. the areas of solid wastes, transportation of radioactive materials and radioactive waste, ard inspector followup'on previously. identified inspection finding Results:

Based upon the results of interviews with licensee management, supervision, health physics technicians, and personnel from different departments, review of records; inspector observations; and health physics personnel knowledge of functions and responsibilities regarding department operations; the inspector found the solid radwaste and transportation of radioactive materials program to be adequately managed and effectively controlled. The licensee had an effective audit program in the area of solid waste and transportatio One licensee-identified violation was identified (Paragraph 2).

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REPORT DETAILS Persons Contacted Licensee Employees

• Bcwling, Assistant Station Manager W. Cameron, Superintendent of Radwaste Project (Corporate)

G. Clark, Supervisor, Quality and Auditing

• R. Driscoll, Manager, Quality Assurance R. Evans, Assistant Health Physics Supervisor, Raduaste H. Hay, Quality Assurance Auditor

• P. Kemp, Supervisor, Licensing

• D.-Lowman, Senior Health Physicist (Corporate)

'D. Ross. Supervisor, Health Physics

• A. Stefford, Superintendent Health Physics

• W. Thorton, Director, Health Physics and Chemistry (Corporate)

S. Tipswood, Senior Instructor Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne * Attended exit interview Solid Waste (84722)

10 CFR 20.311 (d)(1) requires that any generating licensee who transfers radioactive waste to a land disposal facility prepare all waste so that the waste is classified according to 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.5 The inspector reviewed radioactive waste classification documentation for selected radioactive waste shipments and determined that the waste had been properly classified and met the waste characteristics requirements of 10 CFR 6 The inspector also reviewed Deviation Report 89-1188, dated May 30, 1989, which described an error in the efficiencies used for gamma scanning composites of smears and filters. This error was initially identified by the licensee's vendor who performs the various waste stream analyse After the licensee became aware of the errors in the efficiencies, a deviation report was written and corrective actions were initiate Thirteen dry active waste (DAW) shipments were affected over a time period from March 3, 1988 to May 25, 1989. The use of the incorrect efficiencies resulted in underestimating the total quantities shipped by a factor of The licensee's corrective actions included reviewing the 13 shipments in questio It w6s determined that all the shipments were classified correctl Additionally, the licensee notified the regulatory affairs personnel at the waste burial facility and the State of South Carolin _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ - _ .

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As a result, the licensee created two new waste manifests which corrected the amount of radioactive material actually shipped to the burial facility. The licensee also sent a letter to the supercompaction facility which corrected each of the nine shipments they received. The remaining-two shipments were not revised since they were sent to a waste processing and recovery facility who performs its own analysis before shipping the waste to a burial facilit ' The licensee proposed several long term corrective actions to prevent .

recurrence. Some of the items being considered included:

Initiate a confirmatory measurements program with the vendor laborator *

Perform an audit of the vendor's quality assurance and quality contrul program for radiological analyse *

Require the vendor to be on the licensee's approved vendor lis .

Consider using another vendor to perform the radiological analyse Technically, the licensee was in violation of 10 CFR 20.311(b) and 49CFR172.203(d)(iii). 10 CFR 20.311(b) requires that each shipment of radioactive waste to a licensed land disposal facility must be accompanied by a shipment manifest that indicates as completely as practicable: a physical description of the waste; the volume; radionuclides identity and quantity; the total radioactivity; and the principal chemical for CFR 172.203(d)(iii) requires that the description for a shipment of radioactive material must include the activity contained in each package of the shipment in . terms of curies, millicuries, or microcurie The apparent violation was discussed with Regional personnel and since all the requirements specified in 10 CFR Part 2, Appendix C, Section V were satisfied, this violation is not cite The licensee was informed that this area would be considered a non-cited violation (NCV)

(NCV: 50-338/89-19-01 and 50-339/89-19-01).

During tours of the licensee's waste processing areas and through interviews with radwaste personnel, the inspector observed that the licensee had no onsite provisions for the storage of solid radwast Additionally, the licensee was not solidifying easte onsit Any waste that required solidification was dewatered in an area designated as the waste solidification building and shipped to an offsite waste processing vendor for solidificatio The only other solid waste processing performed onsite was the compaction of 55 gallon drums containing DAW from outside areas and the auxiliary building. The compaction activities were located in the Decon Bay area. The compacted DAW was shipped to an offsite supercompaction facilit During this refueling outage, the licensee had started shipping uncompacted DAW from the containment building directly te the offsite supercompaction facility by way of " Sea Vans." Dose savinos to the radwaste handlers of approximately 50 percent

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were realized due to reduced _ handling times and stay times where the uncompacted DAW was temporarily store The inspector also discussed witi: licensee personnel the New Radwaste Facility (NRF) under construction adjacent to Units 1 and 2 on the site previously designated for cancelled Units 3 and 4. Its construction is presently on hold until funding for its completion is available in 199 The processing and treatment of primary filters and resins will still be performed at the plant, however the following processing systems will be located at the NRF: (1) liquid waste system; (2) Taundry drain system; (3) dry active waste system; (4) spent ion-exchange resin handling system; and (5) asphalt solidification system. Additionally, the NRF will have storage capability for containers of primary resins and filter The inspector reviewed the licensee's radwaste procedures to ensure that approved methods were established to: (1) classify wastes pursuant to 10 CFR 61.55; (2) assure that wastes met the characteristics of 10 CFR 61.56; (3) prepare waste manifests pursuant to 10 CFR 20.311; (4)

mark packages with the class of waste pursuant to 20.311(d)(2); and (5)

investigate-lost shipments pursuant to 10 CFR 20.311(h). The following procedures were reviewed and found to be comprehensive and well-written:

HP-7.1.10, Radioactive Material Control Program, September 1,198 HP-7.1.11, Radioactive Material Control Program Evaluation, September 1, 198 HP-7.1.40, Packaging and Shipment of Radioactive Material, September 1, 198 HP-7.2.10 Solid Radioactive Waste Control Program, December 22, 198 HP-7.2.20, Process Control Program, December 22, 198 "

HP-7.2.21, Sampling. Analyzing and Classifying Solid Radioactive Waste, December 22, 198 HP-11.0.10, Radiological Incident Investigation and Analysis Program, December 29, 198 The licensee occasionally ships small packages of contaminated samples for analysis by U. S. mai The HP supervisor was aware of the general requirements for mailable packages, but was not aware of the recent limitation placed on the activity content for such packages to one-tenth of the activity in a " limited quantity" package under 49 CFR regulation The licensee was noted to be taking immediate action to insert a relevant clause noting such limitations in the existing procedure for mailing of radioactive packages.

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The licensee is currently sampling waste streams annually and shipping the samples to a vendor for analysis. The licensee used the-analysis results to determin: the site-specific scaling factors used for waste classificatio Four different types of waste streams were sampled: DAW (five different package types were sampled); powdex resin; bead resin, and cartridge filter The inspector reviewed the latest sample results and verified that the scaling factors were adjusted accordingl the licensee uses a vendor-supplied computer program (RADMAN) which

. processes input information obtained from a package of waste to determine packcoe's waste classification and transportation type. The program identifies the non-gamma emitters based on the site-specific scaling factors for the particular waste stream from which the waste was generate The program correlates radiation levels and activity contents as a function of time and generates a form for use in preparing shipping paper . Transportation (86740)

10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who deliver licensed material to a carrier for transport to comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 18 The inspector reviewed the records of selected shipments of radioactive material performed in 1989. The shipping manifests examined were prepared in accordance with 49 CFR 170-189 requirements and the radiation and contamination survey results were within the limits specified for the mode of transport and shipment classificatio The inspector reviewed the applicable procedures which incorporated quality control checks to ensure- the appropriate waste classification, stability characteristics and manifest reporting were reviewed prior to each shipmen Additionally, the inspector reviewed the shipping records associated with radioactive materials shipment 89-019. In that shipment steam generator tube plugs were shipped in a DOT Spec. 7A package. The inspector reviewed the records of the licensee's determinations that the package had been fabricated in accordance with an approved design as specified in D0T specification The inspector also reviewed the following quality assurance (QA) audits and assessments that focussed on radioactive waste control shipments:

Functional Evaluation (Corporate Office): Radioactive Waste Management, June 29 - July 3, 198 *

N-88-12, Process Control Program, July 14 - October 5, 1988

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I N-89-18, Process Control Program, February 20 - April 7, 198 Discussions were held with the station QA Audit Supervisor and the lead auditor for. conducting the audits of waste processing / transportation. The audits were found to be well planned and well documented, containing items of substance relating to the radwaste/ transportation program. The reports of audit findings to management were also reviewed and found to contain responsive commitments by management to effect corrective actions for the few deficiencies which had been note The inspector reviewed records and interviewed radwaste personnel to determined if any transportation incidents had occurred.within the last year. The licensee stated that there had been no violations cited by the State of South Carolina for radwaste shipments made to Barnwell during the last two year There was, however, a transportation incident on March 27, 1989, involving a reactor coolant pump shipment to the Westinghouse Facility in Cheswick, PA. In that event, the structural supports of the trailer transporting the reactor coolant pump failed at i Route 522 and Route 719 near Louisa, V The transport package remained intact and therefore radioactive material was contained. After reviewing the licensee's report, it was apparent that the reporting requirements of 49 CFR 171.15,10 CFR 20 and 10 CFR 50 did not appl The licensee notified the NRC Region II office by telephone on March 27, 198 The inspector also reviewed the training program for personnel involved in radwaste and shipping. A four day retraining program in shipping and solid radwaste was provided once every two year In general, the licensee provided 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year in health physics (HP) refresher trainin The HP refresher training program was referred to as Health Physics Technical Development Program (HPTDP). The inspector reviewed HPTDP Module 21 (Radioactive Material Control) and Module 22 (Radioactive Waste Processing). Those modules contained lesson plans in the areas of:

radioactive material control, receipt of radioactive material, packaging, shipments, quality control, solid radioactive waste, solid radioactive material storage requirements, and process control program. The inspector reviewed the training records of the individuals responsible for solid radwaste and noted that those individuals last received training in radwaste in August 198 . Reporting and Analysis of Events (83750)

The inspector reviewed a report dated June 6, 1989, involving a contract worker who exceed his administrative dose control point to the right elbow on May 31, 1989. The worker was conducting Foreign Object Search and Retrieval (F05AR) work on Unit 1 "C" steam generator. The total quarterly dose to the whole body was 2306 mrem, which was 56 mrem in excess of his 2250 mrem administrative control poin No personnel contamination was involved in this event. The inspector reviewed the contributing factors, which included: (1) the workers did not follow the HP technician's directions; (2) none of the three steam generator workers contacted the HP technician either immediately prior to or during the second entry into the

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steam generator; (3) the camera / fiber optic scope became stuck and no documented procedures or guidelines were available regarding freeing the camera or minimizing the potential of it becoming stuck; and (4) the HP technicien did not interrupt abnormal job activities, prevent the entry, nor minimize the duration of the entry. General area dose rates were approximately 60-80 mR/hr. Dose rates in the steam generator, near the tube sheet, were approximately 4-6 R/h The inspector observed that this event was documented in a timely manner and sufficiently detailed; and that it was adequately analyze The inspector reviewed the recommended corrective actions to prevent recurrence, which included the following: (1) require the Station Manager and Superintendent of HP to address all station workers, stressing the importance of adherence to radiological controls and the potential of disciplinary action if controls are not followed; (2) revise the maintenance procedure to address abnormal work sequences in F0SAR; (3)

revise the Radiation Protection Jobs Guidelines to better address and define technician to worker line-of-sight when continuous HP coverage is specified; and (4) incorporate lessons learned from this event into the HP Technician Retraining Industry Events Module. The inspector indicated that the effectivenesses of the corrective actions would be evaluated once they are implemente . Licensee Actions on Previously Identified Inspection Findings (92701, 92702) (Closed) Violation 50-338/87-24-03 and 50-339/87-24-03: Failure to verify radiation monitor 1-RM-SV-121 operability through a daily channel check. The inspector verified that the corrective actions documented in the licensee's response letter to the NRC dated November 4,1987 had been implemente The inspector observed that the applicable performance test procedure required both the trend and the readout of the air ejector radiation monitor to be evaluated once per four hour The evaluation provided an independent means of verifying operability of the air ejector monitor where by the monitor reading would be compared against post data and leak rate trend The performance test procedure also required that the high alarm set point be reviewed once per fcur hours to ensure that the alarm will actuate when the primary to secondary leak rate increases by no more than 20 gallons per day. This item is considered close (Closed) Inspector Followup Item (IFI) 50-338/88-03-03 and 50-339/88-03-03: Develop station policy to control containment building entries at full power. This finding was identified during a special ALARA appraisal conducted at the licensee's facility during the week of March 14-18, 198 The inspector reviewed the licensee's response to this finding in a letter to the NRC dated September 16, 198 Basically, licensee management required that a detailed pre-job briefing be conducted between Health Physics and the work crew, prior to containment entries at powe Additionally, station administrative procedure, ADM-20.9, Containment Entry ar.J

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l l Exit Under Subatmospheric Conditions, October 27, 1988, was revised to require approval from the Station Manager or Assistant Station Manager for entries with the containment .subatmospheric, includi entries at power. This item is considered close . Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on June 8,198 The inspection summarized the scope and findings of the inspection, including the NC The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents or processes as proprietary. Dissenting comments were not received from the license Item Number Description and Reference 50-338, 339/89-19-01 NCV - Failure to quantify correctly the curie content of 13 DAW shipments per 10 CFR 20.311(b) and 49 CFR 172.203(d)(iii)

(Paragraph 2).

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