IR 05000338/1993012
| ML20035F291 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/06/1993 |
| From: | Robert Carrion, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035F287 | List: |
| References | |
| 50-338-93-12, 50-339-93-12, NUDOCS 9304210118 | |
| Download: ML20035F291 (18) | |
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NUCLEAR REGULATORY COMMISSION
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101 MARtETTA STREET.N.W.
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APR T 1993 Report Nos.:
50-338/93-12 and 50-339/93-12 Licensee: Virginia Electric and Power Company Glen Allen, Virginia 23060 Docket Nos..:
50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2 Inspection Conducted-March 8 - 12, 1993 Inspector
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'R. 9.' Carrion, Radii (tion Sppcialist at4 Signed i
Approved by:
[@ Radiological Protection and Emergency Prepared T. R." Decker,' Chief
' '~Dat6 Signed Radiological Effluents and Chemistry Section Division of Radiation Safety and Safeguards SUMMARY
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Scope:
This was a routine, announced inspection in the following areas:
(1) organization of the Chemistry Department and the units responsible for handling and shipping of radioactive material; (2) plant water chemistry; (3) audits; (4) the Semi-Annual Effluent Release Report; (5) the
Meteorological Monitoring Program; (6) process and effluent radiation
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monitors; (7) the Post Accident Sampling System (PASS); (8) processing and i
shipping of radiological materials; and (9) Inspector followup Item (IFI)
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50-338, -239/91-24-01.
l Results:
The licensee's organization of its Chemistry Department and radioactive material processing and shipping units satisfied Technical Specification (TS)
and Updated rinal Safety Analysis Report (UFSAR) requirements (Paragraph 2).
The licensee had implemented an effective Water Chemistry Program (Paragraph 3).
The licensee's audits were detailed and identified programmatic weaknesses to allow management to take appropriate corrective action (Paragraph 4).
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b 9304210118 930407 PDR ADOCK 05000338 G
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For the second half of 1992, liquid, gaseous, and particulate effluents were i
maintained well within TS,10 CFR 20, and 10 CFR 50 effluent limitations.
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(Paragraph 5).
l The licensee's Meteorological Measurement Program was maintained and met
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functional requirements (Paragraph 6).
The licensee's program for liquid and gaseous processing and monitoring was f
effectively implemented and regulatory requirements were satisfied
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(Paragraph 7).
The licensee's PASS was well-maintained and satisfied TS requirements
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(Paragraph 8).
l Although the licensee had adequate programs in place for the handling and shipping of radioactive material, a licensee-identified violation for the failure to report properly the activity content of a radioactive material shipment was identified (Paragraph 9).
The licensee successfully addressed the issues raised by IFI 50-338, 339/91-l 24-01 (Paragraph 10).
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees J. Breeden, Supervisor, Radiological Analysis E. Dreyer, Supervisor, Radiation Protection
- D. Heacock, Superintendent of Engineering T. Johnson, Supervisor, Radioactive Material Control l
- G. Kane, Station Manager
- P. Kemp, Supervisor, Licensing
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J. Lamberson, Supervisor, Chemistry j
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- J. Leberstein, Staff Engineer, Licensing l
- J. O'Hanlon, Vice President - Nuclear Operations
- B. Shriver, Assistant Station Manager NS&L
- J. Smith, Manager, Quality Assurance i
- A. Stafford, Superintendent of Radiation Protection
- J. Stall, Assistant Station Manager
- F. Thomasson, Corporate Health Physics
- W. Thornton, Director, Chemistry and Health Physics l
Other licensee employees contacted during this inspection included engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission
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- S. Lee, Resident Inspector l
- D. Taylor, Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the l
last paragraph.
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2.
Organization (84750 and 86750)
Technical Specification (TS) 6.2 describes the licensee's onsite and
offsite organizations.
The inspector reviewed the licensee's organization, staffing levels, and lines of authority as they related to the Chemistry Department, Radioactive Material Control Unit, and the Decontamination Waste Unit to l
verify compliance with the TS and Updated Final Safety Analysis Report l
(UFSAR) requirements and to assure that adequate control of radioactive material to prevent / mitigate radiation exposures to the general public and plant personnel was maintained.
l The inspector interviewed the Superintendent of Radiological Protection, who reported directly to the Station Manager and whose organization included five departments: Health Physics (HP) Operations; HP Technical
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Services; Nuclear Chemistry; Radiation Engineering; and Radwaste HP
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Operations. Units responsible for the handling and shipping of
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radiological materials were divided between Radwaste HP Operations and HP Technical Services, with packaging activities being the i
responsibility of Radwaste HP Operations and shipping activities being
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the responsibility of HP Technical Services.
There was one vacancy; for the Supervisor of Radwaste HP Operations. The Supervisor of HP
Operations also served as the Acting Supervisor of Radwaste HP
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Operations at the time of the inspection. The license had no immediate plans to fill the vacancy. As referenced in Inspection Report 50-338, i
339/92-27, an unfilled position for a technician in the unit responsible
for the packaging of radioactive material had been phased out as of l
January 1, 1993. There were no other vacancies in the units responsible j
for packaging and shipping of radioactive material. There had been no changes in the Nuclear Chemistry Department since the last inspection.
i The inspector concluded that TS and UFSAR requirements had been
satisfied.
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No violations or deviations were identified.
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3.
Plant Water Chemistry (84750)
During this inspection, Unit I was in the midst of its ninth refueling outage, which began on January 4,1993 and was scheduled to be completed
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by April 22, 1993.
Unit 2 was in its ninth fuel cycle and producing
power at 100 percent of capacity.
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a.
Primary Water Chemistry
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TS 3.4.7 specifies that the concentrations of dissolved oxygen j
(DO), chloride, and fluoride in the Reactor Coolant System (RCS)
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be maintained below 0.10 parts per million (ppm), 0.15 ppm, and l
0.15 ppm, respectively, during steady state operation. TS 3.4.8
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specifies that the specific activity of the primary coolant be
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limited to less than or equal to 1.0 microcuries/ gram (vCi/g) dose
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equivalent iodine (DEI). These parameters are related to i
corrosion resistance and fuel integrity. The oxygen parameter is
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based on maintaining levels sufficiently low to prevent general and localized corrosion. The chloride and fluoride parameters are
based on providing protection from halide stress' corrosion.
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specific activity parameter is based on minimizing personnel i
radiation exposure during operation and maintenance.
j Pursuant to these requirements, the inspector reviewed daily
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summaries far Unit 2 which correlated reactor power output to
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chloride, fluoride, and dissolved oxygen concentrations, and
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specific activity of the reactor coolant for the period of
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January 1, 1993 through February 22, 1993 and determined that the
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parameters were maintained well below TS limits. Typical values for D0, chloride, and fluoride were less than five parts per
billion (ppb), less than three ppb, and less than one ppb,
respectively.
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Typical DEI values at steady-state conditions ranged from 1.58E-2 pCi/g to 9.14E-3 pCi/g. Also, pursuant to TS 6.9.1.5.c, the license had submitted its Annual Specific Activity Report on
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l February 24, 1993, which stated that there were no instances where
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j results of specific activity analyses of the primary coolant
exceeded the limits of TS 3.4.8.
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Unit 2 had shown evidence of a fuel defect event near the end of December 1992 by a small spike in the DEI trend. One fuel rod was estimated to have one small defect. The licensee had initiated an action plan which included the following recommendations:
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Continue to monitor and trend the primary coolant radiochemistry for any additional anomalies.
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Review power history data prior to the time of apparent fuel failure.
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Plan for fuel examinations during the next refueling outage to identify any defective fuel rods.
Following the examinations, investigate potential failure mechanisms.
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J necessary, redesign the core of the next fuel cycle to ensure that no defective fuel assemblies are reused.
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i The licensee planned to perform an ultrasonic test (UT) inspection
on all fuel assemblies during the next refueling outage.
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In Unit 1, two defective fuel rods had been removed during the current outage. The defects were believed to be the result of debris fretting and/or baffle jetting.
l The inspector concluded that the Primary Water Chemistry was maintained well within the TS requirements.
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Secondary Water Chemistry
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i During the last inspection (92-27), the_ licensee's analytical t
capabilities were exercised in the area of non-radiological water
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chemistry.
(Refer to Inspection Reports (irs) 50-338,-339/92-27, l
Paragraph 4.) Generally, the licensee's analytical results were
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in agreement with the NRC-known values of the standards analyzed.
However, none of the results obtained by the licensee for the i
three concentrations of sulfate anions analyzed were within three standard deviations of the known value. At that time, the licensee planned to review its procedures for sulfate analysis for possible inadequacies.
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The inspector interviewed the Chemistry Supervisor for the current status of the resolution of the issue. The inspector was told that a detailed review of the procedures had found no inadequacies. The possibility of sulfates leaching from the laboratory glassware was checked but no evidence to support the hypothesis was uncovered. A review of statistics of sulfate analyses compiled by the Quality Control (QC) Department for the period from December 1986 through September 1992 determined that 2.3 percent and 5.1 percent were unacceptable low and unacceptable high, respectively, of a sample population of 176. A broader review of all analyses results for the period from December 1986 i
through December 1992, showed that 92.9 percent of the results were acceptable. These reviews indicated that the licensee's analytic capability was good for the period reviewed.
The licensee suggested that a possible reason for the
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discrepancies was the large dilutions required to reduce the concentrations of the standards submitted for analysis to the l
range for which the licensee's analytic equipment was calibrated.
The licensee used a dilution factor of 1:3333 to accomplish that.
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Very small differences in dilution could result in very large.
differences in the final analytic results at the low concentrations.
During the week of the inspection, the Virginia Electric and Power Company (VEPCO) Systems Laboratory prepared standards of approximately 100 ppb, 500 ppb, and 1000 ppb for the licensee to analyze. The licensee successfully analyzed each of the samples.
The inspector concluded that the licensee had presented sufficient evidence to demonstrate its ability to accurately analyze samples for the presence of sulfates.
The inspector concluded that the licensee had implemented a Chemistry Program capable of detecting both Primary and Secondary Side chemistry parameters to ensure safe and reliable plant operation.
No violations or deviations were identified.
4.
Audits (84750 and 86750)
TS 6.5.2.8 specifies the types and frequencies of audits to be conducted under the direction of the Management Safety Review Committee (MSRC).
In order to evaluate compliance with the TSs and assess quality of the
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licensee's audit programs, the inspector reviewed Quality Assurance
Audit 92-03, an assessment of the Off-Site Dose Calculation Manual
(0DCM) and Process Control Program (PCP) to ensure effective i
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i implementation in accordance with regulatory requirements, commitments, and established licensee programs and procedures. The audit field investigation was conducted from January 13 to February 6, 1992, using both performance-and compliance-based techniques and included
observations of activities being performed, personnel interviews, area i
walkdowns, and procedure / document reviews. The audit team was supplemented by specialists from Corporate Nuclear Safety and Corporate l
Health Physics.
During the course of the audit, radioactive material control; processing, packaging, and shipment of radioactive waste; offsite dose calculations of radiological effluents; radiation monitors and their setpoints; radiological effluent measuring instrumentation; and unplanned releases of radioactive material were evaluated. The
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data / observations were categorized by functional area with a short clearly-stated description, and indicated as a strength / weakness, if
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appropriate, with an explanation for a given strength / weakness. The
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audit was found to be well-planned and documented, with a clearly-
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It also included conclusions which identified detailed
findings of both strengths and weaknesses for management consideration.
The results of the audit concluded that the ODCM and PCP were
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effectively implemented, it identified one finding, three observations, l
and three enhancement items for management review and consideration for
action.
A detailed review of previously-identified issues as a result of the 1991 audit was also performed to determine the adequacy of the licencee's remedial actions.
Based on the audit reviewed, the inspector concluded that the licensee's
audit program was capable of identifying programmatic weaknesses and l
making recommendations for corrective action and that the TS audit
requirements were satisfied.
No violations or deviations were identified.
5.
Semiannual Radioactive Effluent Release Report (84750)
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TS 6.9.1.9 requires the licensee to submit a Semiannual Radiological Effluent Release Report within specified time periods covering the
operation of the facility during the previous six months of operation.
The inspector reviewed the semiannual radioactive ef fluent release report for the second half of 1992, issued February 24, 1993. This review included an examination of the liquid and gaseous effluent results for the second half of 1992 and dose estimates for the entire
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calendar year of 1992.
Full year totals for 1990, 1991, and 1992 were compared.
The data are summarized on the following page:
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North Anna Units 1 and 2 Radioactive Effluent Summary
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1990 1991 1992 i
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Unplanned Releases i
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Liquid
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Gas
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Gaseous 1.
Fission and 9.53E+2 2.24E+3 1.23E+3 Activation Gases l
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Iodines 6.31E-3 2.55E-3 1.34E-2
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Particulates 5.95E-4 1.46E-4 1.00E-4
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Tritium 3.10E+1 4.90E+1 4.94E+1 i
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Liquid
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Fission and 6.74E-1.
3.20E-1 3.21E-1
Activation Gases
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Tritium 1.67E+3 1.16E+3 9.29E+2 l
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Gross Alpha
< LLD 2.18E-4 4.73E-4
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f Volume of Liquid Wastes Released 3.62E+8 3.17E+8 2.68E+8 i
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(liters)
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Dose Estimates
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Gaseous Effluents i
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Noble Gas 4.96E-2 1.51E-1 8.84E-2
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Gamma Dose (mrad)
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Noble Gas 1.16E-1 3.38E-1 1.89E-1 i'
Beta Dose (mrad)
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Thyroid (mrem)
2.92E-1 1.19E-1 6.21E-1 i
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Liquid Effluents i
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Liver (mrem)
7.08E-1 6.26E-1 8.42E-1 2.
Whole body (mrem)
6.33E-1 5.27E-1 6.62E-1 No unplanned releases, as defined by the criteria presented in Section 6.6.2 of the ODCM, were reported in 1993 through the date of this inspection.
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The maximum exposed member of the public from the releases of airborne I-131, tritium, and all radionuclides in particulate form with a half life of greater than eight days was identified as an infant, exposed through the grass-cow-milk pathway, with the critical organ being the thyroid gland. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was identified as an adult, exposed by either the invertebrate or fish
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pathway, with the critical organ being the liver.
A comparison of the activity released from liquid fission and activation products, tritium, and gross alpha, as well as gaseous fission and
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activation products, iodines, particulates, and tritium data for 1990,
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l 1991, and 1992 showed no significant changes.
In addition, the dose i
estimates showed no significant changes.
For 1992, North Anna liquid, gaseous, and particulate effluents were maintained well within TS,10 CFR 20, and 10 CFR 50 effluent limitations.
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During this reporting period, changes to the ODCM had been made and included:
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Revision of Attachment 29 to provide justification for using cow-milk R, dose factors and to add new commitment step 3.2.4.
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Revision of Attachments 2, 4,15, and 17 to specify instrument l
mark numbers and clarify instrument surveillance requirements.
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Change of Notes in Attachment 25 to be consistent with the Notes of Attachment 24.
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Minor editorial changes made to Action 1 and Notes 1 and 2 of Attachment 2.
During this reporting period, no extended periods of inoperability occurred with any liquid or gaseous effluent monitoring instrumentation specified in the ODCM.
Evaluation of the land use census conducted in 1992 identified no change
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in sample locations for the Radiological Environmental Monitoring Program (REMP).
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t No major changes to the Radwaste System were identified during the reporting period.
l The report also included the results of solid radwaste shipments. The following table summarizes those shipments for the previous three years.
The shipments typically included spent resins, filter sludges, dry compressible waste, and contaminated equipment.
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i North Anna Solid Radwaste Shipments i
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1990 1991 1992 Volume (cubic meters)
212.6 234.6 386.6 Activity (curies)
724.1 301.2 136.6
For solid radwaste, the inspector noted that the volume was increasing while the activity was decreasing for the three-year period reviewed.
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I The inspector concluded that the Semiannual Radioactive Effluent Release Report was complete and satisfied TS requirements.
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No violations or deviations were identified.
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6.
Meteorological Monitoring Program (84750)
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The information obtained from the Meteorological Monitoring Program is
integral to the determination of offsite dose projection.
l Section 6.6.3.a of the ODCM requires that meteorological data collected
over the previous calendar year be in the form of joint frequency distributions of wind speed, wind direction, and atmospheric stability.
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The inspector reviewed.the Meteorological Monitoring Program at North i
Anna. The review included direct observation, discussions with the i
licensee, and the review of records. The inspector determined that l
North Anna had two meteorological towers, a primary tower and a backup l
tower. The primary tower had two sets of instrumentation, located at i
the 10- and 50-meter levels. Wind speed, wind direction, wind variance, and differential temperature were measured at both levels. Total precipitation, solar radiation, dew point, and barometric pressure
instrumentation were located near ground level, inside the equipment
enclosure. The program utilized a system with a visual display readout
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including wind speed, wind direction, and temperature of both upper and
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lower levels as well as differential temperature and dew point. The
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inspector noted that the location of the tower was as specified by TS 5.5.1 and that there was no interference with the flow of air.
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the event that the tower was out of service, there was a secondary tower which served as a back-up system. The secondary tower provided i
information for wind speed, wind direction, and temperature.
The inspector verified by direct observation.and by records review that the meteorological monitoring instrumentation channels were operable, maintained, and calibrated. The inspector reviewed selected portions of meteorological monitoring instrumentation channel cali'uration records and calibration procedures including:
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ICP-MM-1-SR/ZR-1, " Primary Tower Wind Speed and Direction Monitoring System," Rev. 8
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ICP-MM-1-SR/ZR-2, " Backup Tower Wind Speed and Direction Monitoring System," Rev. 3
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ICP-MM-1-RG-1, " Precipitation Monitoring System," Rev. 4
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ICP-MM-1-DP-1, " Dew Point Measuring System," Rev. 7
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ICP-MM-1-S-1010, " Backup Weather Tower Wind Speed Recorder,"
Rev. 4 The calibration of the various meteorological instrumentation sensors was performed by personnel from the Air Quality Group from VEPC0's l
l Lakeridge Park, Virginia office. The calibration of the various electronic readout recorders was performed by the plant's Instrumentation and Controls (I&C) Group.
Personnel from this unit performed quarterly calibrations,-although the TSs required only semiannual calibrations.
Based on the scope of this review, the inspector determined that the Meteorological Measurement Program was capable of fulfilling its required functions.
No violations or deviations were identified.
7.
Process and Effluent Monitors (84750)
a.
Status of Monitors ODCM Sections 6.2 and 6.3 define the operation and surveillance requirements for monitors of radioactive (or potentially radioactive) streams. This instrumentation is provided to monitor and control the releases of radioactive materials during normal and abnormal plant conditions as well as in effluents during
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effluent releases. The alarm / trip setpoints for the effluent monitors are calculated in accordance with the procedures of Sections 6.2.2 and 6.3.2 of the ODCM to ensure that the alarm / trip will occur prior to exceeding the limits of 10 CFR 20. The alarm / trip setpoints for the process monitors are specified by Section 3.3.3.1 of the TSs.
The inspector walked down twenty-six radiation monitors, including four effluent monitors, to become familiar with their physical location in the plant and to observe their state of maintenance and operability. The following monitors were included:
RM-VG-179-1; RM-VG-179-2; RM-VG-180-1; RM-VG-180-2; l-RM-GW-101; l-RM-GW-102; l-RM-GW-173; l-RM-SS-122; l-RM-SS-123; l-RM-SS-124; l-RM-SV-121; 1-RM-VG-103; 1-RM-VG-104; l-RM-VG-105; l-RM-VG-106; l-RM-VG-ll2; l-RM-VG-ll3; 1-RM-VG-159; 1-RM-VG-160; l-RM-VG-174; l-RM-VG-175; 2-RM-SS-222; 2-RM-SS-223; 2-RM-SS-224; 2-RM-VG-259; and 2-RM-VG-260. Of these monitors, two (2-RM-VG-259; and 2-RM-VG-260) were found to be out of service due to an intermittent
" low flow" alarm and the inability to measure a vacuum in the
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written on December 19, 1992 for 2-RM-VG-259 and Work Request
009410 had been written on January 13, 1993 for 2-RM-VG-260. All
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other monitors were found to be well-maintained and operable.
l The inspector concluded that the program for maintaining the l
i plant's process and effluent monitors was being successfully implemented.
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Release Permit Review
Sections 6.2.1, 6.2.3, 6.2.4, 6.3.1, 6.3.3, 6.3.4, and 6.3.5 of the ODCM define the requirements for liquid and gaseous effluent l
concentrations, doses and dose rates, and waste treatments l
released to unrestricted areas. These requirements are intended
to ensure that the limits of 10 CFR 20 and 10 CFR 50 are satisfied.
Section 6.1 of the ODCM defines the criteria for
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sampling and monitoring.
f The inspector reviewed one randomly-selected Liquid Release Permit (93-MLBATCH-29) and two randomly-selected Gaseous Release Permits (93-VV-2 and 93-VV-8) from since January of this year to verify j
compliance. The permits included both release information and
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j projected dose calculations and were found to be complete, l
including the identification of the source of the release, the
activity released (identified by isotope), and the volume of the
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effluent discharged.
The inspector concluded that the licensee's program for liquid and gaseous processing and mor.itoring was being effectively implemented and that regulatory requirements were satisfied.
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140 violations or deviations were identified.
8.
Post Accident Sampling System (PASS)
l NUREG-0737 requires that the licensee be able to obtain a sample of the reactor coolant and containment atmosphere.
Furthermore, the sample
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must be promptly obtained and analyzed (within three hours total) under
accident conditions without incurring a radiation exposure to any l
individual in excess of 3 and 18 3/4 rem to the whole body or
extremities, respectively.
Furthermore, TS 6.8.4.d requires that a
program shall be established, implemented, and maintained which will l
ensure the capability to obtain and analyze reactor coolant, radioactive
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iodines and particulates in plant gaseous effluents, and containment l
l atmosphere samples under accident conditions. The program shall
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include:
training of personnel; procedures for sampling and analysis;
and provisions for maintenance of equipment.
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I The inspector walked down the PASS control panel to observe its physical
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condition.
Discussions with cognizant licensee personnel outlined l
various features and operational capabilities of the system. The PASS
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was found to be well-maintained.
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The inspector reviewed the following periodic tests performed by the l'
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1-PT-53.3, " Reactor Coolant System Specific Activity - I-131 Dose
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Equivalent Analysis," Rev.11 j
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2-PT-200.1, "HRSS Containment Air Sampling Operability Test and
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Chemistry Technical Training," Rev. 5
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2-PT-200.3, "HRSS LSP Operability Test and Chemistry Technical l
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Training," Rev. 2
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1-PT-53.1, " Reactor Coolant System Chemistry and Specific l
Activity," Rev. 20
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Surveillances using the first two procedures were required on a bi-t weekly basis.
The inspector reviewed the results of the surveillances i
done using 1-PT-53.3 for the period of November 11, 1992 through l
December 23, 1992. Surveillances were done on Novemoer 11 and 25 as
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well as on December 9 and 23 and were found to be satisfactory.
l Surveillances using procedure 2-PT-200.3 was required on a monthly
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basis. The inspector reviewed the results of those surveillances done l
on January 7 and February 9,1993 and found them to be satisfactory.
l Surveillances using procedure 1-PT-53.1 was required on a 72-hour basis, o
The inspector reviewed the results of surveillances done for late i
December 1992 including December 21, 23, 25, 28, and 30 and found them
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to be satisfactory.
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The inspector concluded that the PASS was being well-maintained and that
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the licensee satisfied TS requirements.
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l No violations or deviations were identified.
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9.
Radwaste Processing and Transportation (86750)
10 CFR 71.5 (a) requires that each licensee who transfers licensed material outside of the confines of its plant or other place of use, or i
who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the i
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l mode of transport of the Department of Transportation (DOT) in 49 CFR, i
Parts 170 through 189.
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Pursuant to these requirements, the inspector reviewed the licensee's activities affiliated with these requirements to determine whether the licensee effectively processes, packages, stores, and ships radioactive
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material s.
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The licensee's program for the processing (including separation and
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compaction) and packaging of radioactive materials, including solid i
l radwaste, was conducted by the Decontamination Unit within the Radwaste
HP Department. The licensee's program for the transportation of
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radioactive material was conducted by the Radioactive Material Control i
Unit within the HP Technical Services Unit and was responsible for loading shipments and preparing shipping documentation.
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a.
Observation of a Shipment
On March 10, 1993, the inspector observed Shipment No. 93-QUAD-16, j
two Sea-Land containers of Low Specific Activity (LSA) material,
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Dry Active Waste (DAW), destined for Quadrex for processing. The
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inspector reviewed the records of the shipment prior to its leaving the site. The radiation and contamination survey results i
were well within regulatory limits for highway transport. The
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shipping manifest examined was consistent with the DOT
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requirements, including the 24-hour emergency telephone number as j
specified in 49 CFR 172.201(d). The inspector surveyed the j
shipment before it left the site to verify the licensee's survey
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and determined that it was accurate.
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Based on this review, the inspector concluded that the shipment
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was handled according to the licensee's procedures and was j
properly documented.
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b.
Radwaste Shipping Documentation The inspector reviewed shipping logs for 1992. The licensee classified shipments into three categories: Radiological Material
Receipts; Radiological Material Shipments; and Radwaste Shipments,
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which were further identified as shipments to the disposal l
facility, Scientific Ecology Group, Inc. (SEG), and Quadrex.
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l Radiological Material Receipts included items such as decontaminated outage and refueling equipment, empty Sea-Land container:, and laundered protective clothing and modesty garments.
Radiological Material Shipments included items such as contaminated outage equipment, radioactive material samples, and laundry.
Radwaste Shipments included radioactive material ultimately destined for disposal.
The logs showed that for 1992, there had been 136 Radiological Material Receipts,136 Radiological Material Shipments (including one (92-RMS-135) for which the paperwork was completed in December but was not actually
shipped until early January), and 40 Radwaste Shipments (18 directly to the disposal facility, 21 to SEG, and one to Quadrex).
The logs also showed that for the 1993 calendar year to date (March 10, 1993), there had been 85 Radiological Material Receipts, 72 Radiological Material Shipments, and 20 Radwaste Shipments (4 directly to the disposal facility and 16 to Quadrex).
The inspector reviewed three Radwaste Shipment documentation packages, 9304, 93-QUAD-12, and 93-QUAD-13, for completeness and compliance with the regulations. The packages do'.umented the
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- shipments and included items such as unique shipment and shipping container numbers, waste content and volume, total activity, analytical summary and breakdown of isotopes with a half-life greater than five years. The radiation and contamination survey results were within the limits specified and the shipping
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documents were being maintained as required.
c.
Non-Cited Violation (NCV) 50-338, 339/93-12-01, Failure to Report Properly Activity Content of Radioactive Material Shipment I
On February 1,1993, Radioactive Material Shipment 93-RMS-030 was released for transport with inaccurate information specified on the shipping paperwork. Specifically, the total activity was incorrectly listed on the Radioactive Material Transfer and l
Shipment Record and did not meet the requirements of l
49 CFR 172.202(a)(5) and 49 CFR 172.203(d)(4). Also, two l
prominent nuclides were incorrectly listed on the Bill of Lading, l
in violation with 49 CFR 172.203(d)(2).
During a documentation review by the licensee on February 5, 1993,
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the errors were discovered. The licensee initiated Deviation l
Report N-93-283 and established a review team to determine the
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cause of the errors and develop preventive / corrective actions as l
well as remedial actions.
Immediate remedial actions included l
correcting the shipping papers and adding them to the shipping package, notifying the consignee by telephone, and sending to the l
consignee a corrected copy of the shipping papers. Also, to ensure that this was an isolated event, the licensee reviewed shipping papers for all previous 1993 Radiation Material Shipments. No other major discrepancies were discovered.
(However, two minor discrepancies were found, one where total shipment weight was off by one hundred pounds and another where the contact dose rate was off by one millirem.
Copies of the corrected manifests were sent to the consignees.) The review team determined the cause to be the result of inattention to detail and a calculation error (the manual calculations were not performed on the required data sheet but rather by editing a previous manifest)
coupled with an inadequate independent review of the paperwork.
The review team made the following recommendations to prevent recurrence of the event:
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Require the shipment paperwork to be independently verified by a second individual qualified on radioactive material shipments prior to supervisor approval.
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Include radioactive material shipments as part of the QA surveillance program.
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Evaluate the use of a radioactive material shipment computer program to reduce the opportunity for erro _
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Evaluate the currently-used shipping paper format for i
enhancement in consideration of human factors.
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Revise radioactive shipment training to emphasize _
responsibilities for processing shipping paperwork.
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Provide a quiet environment for processing shipping
paperwork.
This licensee-identified violation is not being cited because the I
criteria specified in Section V.II.B.(2) of the Enforcement Policy
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were satisfied.
It is documented as NCV 50-338, 339/93-12-01:
failure to report properly activity content of radioactive material shipment.
d.
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The inspector discussed IN 92-72, " Employee Training and Shipper l
j Registration Requirements for Transporting Radioactive Materials,"
i with cognizant licensee personnel to be sure that the licensee had
received it and that the staff was aware of its implications in l
ensuring regulatory compliance when shipping packages containing radioactive materials. The licensee was reviewing the issues raised to assure that they were addressed in training which was
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scheduled for the summer.
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The inspector concluded that the Radwaste Group was staffed by competent personnel who effectively implemented the program. Although one NCV was i
identified, the response by the staff was timely and professional to preclude recurrence and to assure that any radiological conditions resulting from the incident were mitigated.
l One licensee-identified violation was identified.
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i 10.
Status on Previously-Identified Inspection Findings (92701)
(Closed) IFI 50-338, 339/91-24-01:
Review of the availability of the high radiation sample system (HRSS) gas chromatograph.
The inspector reviewed licensee actions related to this item. The original problem was that the columns of the gas chromatograph would not separate the gases.
The licensee thought that the columns would have to be dried out or replaced. Work Order 652549 was submitted on March 14, 1991 to replace the one-and eight-foot columns and the instrument air regulator valve, to adjust flows through the columns, and to balance the bridge. The Work Order was completed on June 10, 1991.
The inspector reviewed eleven randomly-selected monthly status reports which included the gas chromatograph for the period from June 1991 through February 1993.
Except for a period of eight days from November 25 to December 3, 1992, the gas chromatograph had been available. Therefore, the inspector closed the IF.
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11.
Exit Interview
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The inspection scope and results were summarized on March 12, 1993, with l
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those persons indicated in Paragraph 1.
The inspector described the
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areas inspected and discussed the inspection results, including likely informational content of the inspection report with regard to documents
and/or processes reviewed during the inspection. The licensee did not identify any such documents or processes as proprietary. Dissenting
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comments were not received from the licensee.
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Item Number Description and Reference l
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50-338,339/93-12-01 NCV - Failure to report properly activity j
content of radioactive material shipment i
(Paragraph 9.c).
l 12.
Acronyms and Initialisms i
CFR - Code of Federal Regulations
Ci - curie
DAW - Dry Active Waste
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DEI - Dose Equivalent Iodine DO - Dissolved Oxygen
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DOT - Department of Transportation g - gram
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HP - Health Physics HRSS - High Radiation Sampling System I&C - Instrumentation and Controls
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IFI - Inspector Followup Item
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IN - Information Notice IR - Inspection Report LLD - Lower Limit of Detection LSA - Low Specific Activity pCi - micro-Curie (1.0E-6 Ci)
mrad - milli-Rad mrem - milli-rem MSRC - Management Safety Review Committee i
.Non-Cited Violation NRC - Nuclear Regulatory Commission
ODCM - Off-Site Dose Calculation Manual
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PASS - Post Accident Sampling System
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PCP - Process Control Program ppb - parts per billion ppm - parts per million PT - Periodic Test QA - Quality Assurance QC - Quality Control
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R, - dose factor RCS - Reactor Coolant System REMP - Radiological Environmental Monitoring Program
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Rev - Revision i
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i SEG - Scientific Ecology Group, Incorporated l
TS - Technical Specification
UFSAR - Updated Final Safety Analysis Report i
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UT - Ultrasonic Test
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VEPC0 - Virginia Electric and Power Company i
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