IR 05000352/1993017

Insp Repts 50-352/93-17 & 50-353/93-17 on 930706-09.Two Unresolved Items Identified.Major Areas Inspected:Storage, Radioactive Waste Handling,Processing & Transportation Programs

ML20056D498
Person / Time
Site:	Limerick
Issue date:	08/02/1993
From:	Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056D497	List: IR 05000352/1993017 ML20056D496
References
50-352-93-17, 50-353-93-17, NUDOCS 9308170006
Download: ML20056D498 (9)

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U. S. NUCLEAR REGULATORY COMMISSION l

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Report Nos. 50-352/93-17  !

50-353/93-17 j i

Docket Nos. 50-352 l 50-353 l

License Nos. NPR-39  ;

NPR-85 l

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Licensee: Philadelphia Electric Company >

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Correspondence Control Desk P.O. Box 195 j Wayne. PA 19087-0195 Facility Name: Limerick Nuclear Genemting Station. Units 1 and 2

Inspection At: Limerick. Pennsylvania

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Inspection Conducted: July 6-9.1993

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Inspector: -

c<- 9 # 2' ? 3 R. L. Nimitz, CHP, Senior Radiation 4pecialist date j Approved by: *a 2 ~I'.3 W. Pasciak, Chief, Facilities Radiation

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date Protection Section

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Areas Inspected: Announced inspection of the radioactive waste handling, processing, .i storage, and transportation programs. Areas reviewed during the inspection were important to health and safety and included audits and technical monitoring; changes; training and qualifications; procedures and records; radioactive waste handling, and storage; radicactive 3 waste shipping activities; 10 CFR Part 61; and station condition ;

Findines: The inspection identified that generally very good radioactive waste handling, storage, processing, and transportation programs were implemented at Limerick Generating .

Station. The programs were generally well managed with a good level of technical expertise ,

available to support these programs. Two unresolved items were identi6ed. The first !

involved completion of sign-offs for training records. The second involved the method of ,

calculation of curie content of radioactive waste shipping packages. These matters are j discussed in the inspection repor i

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9308170006 930805 PDR ADOCK 05000352 O PDR  !

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DETAILS 1.0 Individuals Contacted During Inspection .f

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1.1 Licensee Personnel

• D. Helwig, Vice-President, Limerick Generating Station

• R. Boyce, Plant hianager

• J. hiittura, hianager, Radwaste Opentions

• L. Wells, hianager, Radwaste Services

• G. Stewart, Engineer-Regulatory '

l G. hiurphy, Senior Health Physicist  ;

• J. Kanter, hianager, Experience Assessment  !

• K.12 timer, Training Instmetor, Radwaste ,

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• R. Tomlinson, hianager, Services Training

1.2 NRC Personnel i

• N. Perry, NRC Senior Resident i i

• Denotes those individuals attending the exit meeting on July 9,199 l

The inspector also contacted other licensee individuals during the course of this inspectio .0 Purnose and Scope ofInspection

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This inspection wr.s a routine, announced inspection of the radioactive waste handling, processing, storage, and transportation programs. Areas reviewed during the -

inspection were:

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audits and technical monitoring 'l

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changes  !

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training and qualifications ,

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procedures and records

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radioactive waste handling, and storage  !

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adioactive waste shipping activities

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10 CFR Part 61 analyses r

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station condition t 3.0 Audits and Technical hionitoring The inspector reviewed audits and technical monitoring of radioactive waste activities, including transportation activities, relative to criteria contained in Technical

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Spe:ifications and applicable licensee procedure !

The evaluation of the licensee's performance in this area was based on review of ;

audits and technical monitoring reports, and discussions with cognizant personnel. In l particular, Audit No. A0712617, LGS Process Control Pmgram, Radwaste Handling . ,

and Shipping, dated April 13,1993, was reviewed as were technical monitoring .

reports for 1992 and 199 !

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The inspector's review indicated an effective quality assurance program for  :

radioactive waste activities was in place. The inspector noted that appropriately -i qualified individuals performed the audits and technical monitoring and audit plans >

were prepared for use by these individual !

The following additional positive observations were made: i

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The Corporate Radiological Controls Group performed an evaluation in 1992 :

of the programs, procedures and activities at the Limerick Station to assum proper waste classificatio ;

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The Corporate Radiological Controls Group also performed an evaluation in early 1991 of radwaste processing and minimization activities at the Limerick Statio l

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The licensee performed technical monitoring of empty fuel shipping cask .

The casks were being handled in preparation for future fuel receipt activitie [

The technical monitoring was considered a very good initiativ i t

The following area for improvement was identified:

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The licensee uses a vendor laboratory to analyze the samples of the various .

radwaste streams at the licensee's facility. The analysis results were used by 3 the licensee for purposes of classification of waste to be shipped and ,

determination of curie content of the waste. There was no apparent formal :

licensee QA oversight of the laboratory or analysis results. However, the ,

licensee's radwaste staff were aware of audits performed by industry radwaste groups. At the time of the inspection, the licensee was not able to provide the i inspector the most recent such audit or discuss the finding. The licensee indicated this matter would be reviewed. This area will be reviewed during i future inspection ,

No safety concems or violations were identifie .

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.i 4.0 Changes ,

The inspector reviewed selected changes made by the licensee since the previous ;

inspection in this area (Refemnce NRC Combined Inspection Repon No. 50-352/91-13; 50-353/91-14, dated May 23,1991). Items reviewed included organization, .

processes, and pmcedure [

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The evaluation of the licensee's performance in this area was based on discussions i with personnel and review of document i The inspector's review indicated there wem no significant changes in the organization and the organization remained stable. The licensee updated the Process Control Program to mflect the new deep bed demineralizers at Units 1 and No safety concerns or violations were identifie l 5.0 Training and Oualifications  !

The inspector reviewed the training and qualification of individuals involved with the storage, handling, processing, transponation, and gener.-t. ion of radioactive wast The review was with respect to criteria contained in the following:

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IE Bulletin No. 79-19, Packaging of Low-Level Waste Radioactive Waste for Transport and Burial, dated August 10,1979

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NRC Information Notice No. 92-72, Employee Training and Shipper

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Registration Requimments for Transportation Radioactive Material, dated October 28,1992, and l

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Limerick Generating Station (LGS) Updated Final Safety Analysis Report :

Table 13.2-1, " Matrix of LGS Training Pmgram Guidelines'

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the licensee's June 27,1991, clarification letter regarding IE Bulletin 79-19

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the following training documents:

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Radwaste Training Program Plan (RW-900)

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Radwaste Shipping Course (RWSP-9100) t

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Radwaste Technician Course Plan (RWT-9100)

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Radwaste Continuing Training (RWCT-9100)

The inspector also reviewed training initiatives implemented by the licensee associated with planned receipt of fuel from the Shoreham Nuclear Power Statio )

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The inspector reviewed organizational chans and shift manning schedules and selected for review those individuals involved with the aforementioned activities. The .;

inspector reviewed the qualification and training documentation, and scope of training for radiation protection personnel, support personnel, and operations personnel. The l inspector also reviewed the training and qualification of radiation workers relative to ;

minimization of radioactive waste. In addition, the inspector reviewed the training of I personnel on new procedures or procedure change Inspector's review indicated that the licensee implemented very good training and that >

verf good continuing training efforts were on-gom :

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The following unresolved item was identined:

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The inspector noted that the licensee established and implemented procedum No. RW 120, Radwaste Group Information Dissemination, to establish a method of dissemination of information or instmetions to Radwaste Tecimical staff or Radwaste Operations personnel. The procedure requires that the items or instmetions be entered on a radwaste information notice log and not indicated as closed, on the log, until all applicable personnel have signed the appropriate item noti 5 cation form contained in procedure RW 120. The inspector noted that the Information Log was signed off on May 2,1993, for -

an information item issued on March 3,1993. The item, No.93-009, dealt ,

with new procedure revisions associated with placing filter-demineralizers in l service. Two individuals, a radwaste supervisor and a radwaste operator, did not sign the information form. It was unclear as to the basis for their not i signing the form or the reason the log item was closed without the signature This item is unresolved. (50-352/93-17-01; 50-353/93-17-01)

No violations were identifie ,

6.0 Procedures and Records The inspector reviewed the procedures and records associated with the radioactive waste storage, handling, and tmnsponation progra l The inspector reviewed these documents relative to criteria contained in applicable licensee administative procedures and Technical Specification 6.8, Procedures. The inspector reviewed changes made in these procedures since the previous inspection in this are ,

The evaluation of the licensee's perfonnance in this area was based on review of procedures and records and discussions with personne ;

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6 l The inspector's myiew indicated that the procedums pmvided genemlly a good level i of guidance to personnel. The inspector noted that the licensee enhanced pmcedures ,

to include suggestions contained in NRC Information Notice No. 92-62, Emergenc '

Response Information Requirements for Radioacdve Material Shipments. The ,

licensee also revised pmcedures to pmvide enhanced guidance for receipt of fuel from i the Shoreham Station. The records of radwaste activities (e.g., shipping records) *

were complete and well maintaine :

The following weakness was identified: l

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The licensee's radwaste staff had a non-controlled copy of radwaste procedures >

in the radwaste work area. During inspector follow-up on changes made by *

the licensee in the area of procedure enhancement, the inspector was pmvided an out-of-date revision of a shipping procedure fmm the non-controlled copie ,

The copy did not reflect the changes made. The uncontrolled procedure copies '!

were subsequently removed. The inspector noted that controlled procedure copies were in the vicinity and that the non-controlled procedures were not located in an openting are :

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The following area for improvement was identified: l

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The procedure for drying of resin did not contain sufficient guidance for use of a relative humidity chart contained in the procedure. In addition, the chart in :

the procedure was difficult to read. The chart pmvided, in part, acceptance j criteria for the drying. The licensee's personnel indicated this matter would be ;

reviewed. Inspector discussions did not identify any deficiencies regarding l resin dryin t No safety concerns or violations were identifie !

7.0 Radioactive Waste Handiing and Storage  !

l The inspector toured the station and reviewed handling and storage of radioactive ;

waste. The evaluation of the licensee's performance was based on independent  !

observations during station tours and discussions with cognizant personnel, t

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The inspector also reviewed the licensee's plans relative to constmetion of an interim on site low level waste storage facility. The inspector met with cognizant licensee l personnel and discussed the plans. The following documents were reviewed relative to the storage area:  !

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FinalInstallation Design Package, Modification No. 6208, Low Level i Radwaste Storage Yard dated December 21,1992 i

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Procedure No. RT-0-RRR-901, Inspection of the Radwaste Storage Pad (RSP), I dated June 18,1992

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Procedure No RW-116, Control of Contaminated Reusable Material on Radwaste Storage Pad, dated October 31,1991

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The inspector's review of storage facilities within the facility indicated the licensee was appropriately storing radioactive wast Regarding the interim radwaste storage area, the inspector noted that the licensee used, in-part, criteria contained in Generic Letter 81-38, Storage of Low-level ,

Wastes at Power Reactor Sites, dated November 10,1981, and 10 CFR 50.59, Changes, Tests and Experiments, for evaluation and design guidance. The facility will be built in phases as needed and located at a separate secured area outside the -

protected area (southwest of the spray pond and northwest of the Unit I cooling tower). Waste forms to be stored at the yard will be limited to dewatered resins, sludges, filters, solidified material, and dry active waste. Volumes of wastes to be stored at the area will be limited to 60,750 ft' (1363 curies) of lower activity resins, material and dry active waste, and 2920 ft' (1423 curies) of higher activity resins and material. The waste will be stored in concrete modules. The structure will be made of concrete (floors, walls and ceiling) which will provide shielding. Off site dose !

evaluations have been performed which indicated operation of the facility will not '

result in any measurable contribution to off site radiation dose rates. No waste will .

be stored beyond five years without specific approva No safety concerns or violations were identifie j 8.0 Radioactive Waste Shippine Activities '

The inspector reviewed radioactive waste shipping activities. The review was with l

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respect to criteria contained in the following:

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10 CFR 71, Packaging and Transportation of Radioactive Material i

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49 CFR Transportation

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applicable licensee procedures .

The evaluation of the licensee's performance in this area was based on discussions with personnel and review of documentatio The inspector selected for review 1992 radioactive waste shipments and other shipments of radioactive material representative of those routinely and non-routinely -

shipped from the site (e.g., de-watered resins, filter cartridges and irradiated L

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hardware). The inspector reviewed applicable documentation (including radiation and I contamination survey data), Part 61 analyses, certificates of compliance, and j procedure adherenc ;

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The inspector's review indicated that the transportation program was generally well '

managed. The licensee maintained comprehensive documentation packages for all out-going shipment l

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No safety concerns or violations were identifie l 9.0 Part 61 Analyses l l

The inspector reviewed the licensee's scaling factors used for radioactive waste !

classification purposes. The evaluation of the licensee's performance in this area was j based on discussions with cognizant personnel and review of procedures. The i inspector reviewed this area relative to guidance and suggestions provided in NRC Information Notice No. 86-20, Low-Izvel Radioactive Waste Scaling Factors,10 :

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CFR Part 61, dated March 28,1986, and the NRC Branch Tecimical Position (BTP)

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on waste classification, dated May 11, 1983. The inspector reviewed all waste streams and waste types genente ;

The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel and review of document ;

The inspector's review indicated that the licensee established and implemented appropriate scaling factors and that factors were being updated in accordance with l recommendations contained within the above BT i The following unresolved item was identified:

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Upon determination of scaling factors, the factors are incorporated into the !

RADMAN computer program. The program is then used to determine the total curie content of a package of waste based on use of a dose rate to curie y conversion factor calculated by the program. To determine total curie loading of the package, radiation dose rates are made at three points on the side of a ;

package (e.g., liner) and at one meter distance from the side. These dose rate !

readings are then used to determine essentially an average dose rate which is t then inputed to the program for calculation of total curie loading. The j inspector's review indicated that it was not apparent that use of the averaging !

formula and the use of the side only dose rates provided a reasonably accumte i (within a factor of 10) quantification of total curie content of the packag ;

This matter is umesolved (50-353/93-17-02; 50-354/93-17-02)  ;

i The inspector also noted that the curie loading of one shipment (No. 93-10) {

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was determined by use, in part, ofliner bottom dose rates. Tids appears to )

not be in conformance with the guidance of applicable procedures. The l calculation however appeared to b+ conservative. The observation indicated an !

apparent need to clarify the procedure or re-instruct personnel. The licensee's i personnel initiated a review of this matte !

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No violations were identifie l l

10.0 Station Tours  :

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The inspector's tours of the station indicated that overall, housekeeping was very !

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11.0 Exit Meeting l

The inspector met with licensee representatives (denoted in Section 1.0) on July 6, j 1993. The inspector summarized the purpose, scope and findings of the inspection, j The licensee acknowledged the inspection finding !

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