IR 05000354/1986044
| ML20215E750 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 10/06/1986 |
| From: | Bicehouse H, Myers L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20215E742 | List: |
| References | |
| 50-354-86-44, NUDOCS 8610150488 | |
| Download: ML20215E750 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No 86-44 I
Docket No.
50-354 License No. NPF-57 Priority Category C
Licensee:
Public Service Electric & Gas Comptny 80 Park Plaza - 1/C Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge, New Jersey Inspcction Conducted:
September 8-12, 1986 Inspectors:
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H. J.' Bicehouse, Radiation Specialist date
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LJ E." My Fs, R diation Spec ialist date Approved bu-
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W. J. Pp:f'ak', Khyef", Ef fhreWRadiation patA Protecti n Section Inspection Summary:
Inspection on September 8-12, 1986 (Inspection Report No. 50-354/86-44)
Areas Inspected:
Routine, unannounced inspection of the licensee's solid radio-active wastas (radwaste) program during startup activities including previously identified items, organization, procedures, Quality assurance / quality control, solid radwaste system, waste generator requirements and planning for packaging /
shipping.
Results: Within the areas reviewed, nu violations were noted.
However, the licensae's reorganization of the radiation protection group was considered unresolvcd pending review of licensee submittals for Final Safety Analysis Report (FSAR) and Technical Specification (TS) changes.
8610130488 861007 DR ADOCK 0500
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DETAILS 1.
Persons Contacted During the course of this routiae inspection, the following personnel were contacted or interviewed:
1.1 Public Service Electric and Gas Company (PSE&G)
- R. S. Salvesen, General Manager, Hope Creek Operations
- R. B. Donges, Licensing Engineer
- J. Gomeringer, Technical Supervisor, Radiation Protection, Salem Nuclear Generating Station
'R. T. Griffith, Sr., Principal Quality Assurance (QA) Engineer B. Hunkele, Senior Supervisor, Radioactive Material Control, Salem Nuclear Generating Station
- M. J. Kobran, Lead Engineer, Radwaste Systems
- P. M. Krishna, Assistant to General Manager, Hope Creek Operations
- J. J. Molner, Senior Radiation Protection Supervisor
- G. T. Morrill, Radiation Protection Supervisor, Effluents
"L. M. Piccirelli, QA Engineer
- L. Silvey, Senior Operations Support Supervisor
- S. Singh, Nuclear Engineer
- G. M. Suey, Chemistry Supervisor Other licensee employees were contacted or interviewed during this inspection.
1.2 Contractors J. Livingston, Startup Group Lead, General Electric Co.
Other contractor employees were contacted or interviewed during this inspection.
1.3 NRC Personnel
- D. Allsopp, Resident Inspector R. Borchardt, Senior Resident Inspector
- Attached the Exit Interview on September 12, 1986 2.
Purpose The purpose of this routine inspection was to review the licensee's solid radioactive waste (radwaste) preparation, packaging and shipping program with respect to the following elements:
Status of Previously Identified Items;
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Organization;
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Quality Assurance / Quality Control Procedures;
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Solid Radwaste System;
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Waste Generator Requirements; and
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Planning for Packaging / Shipping.
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3.
Status of Previously Identified Items 3.1 (0 pen) Followup Item (50-354/85-44-10) Review test results for solid radwaste system.
Preoperational testing of the solid radwaste system had not been completed.
The contracted startup Group Lead and the Lead Engineer indicated that preoperational testirig would be completed by mid December 1986.
The following table summarizes the status of preoperational testing during the inspection.
Test Number Title S_tatus HC-1.01
" Solid RW Auxilary Boiler" Complete HC-1.02
" Solid RW Overhead Crane" Complete l
HC-1.03
"RW Centrifuge" Incomplete
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HC-1.04
"RW Asphalt System" Retest Needed HC-1.05
" Solid RW Sludge Tank and Feed System" Incomplete HC-1.06
" Solid RW Fill Station" Complete HC-1.07
" Solid RW Copper / Conveyor" Complete HC-1.08
" Solid RW Extruder-Evaporator & Peripherals" Complete HC-1.09
" Solid RW Concentrator Feed" Incomplete HC-1.12
" Solid RW Compacter" Complete HC-3.1
" Solid RW Evaporator" Incomplete This item remains open pending completion of the preoperational tests, test result review and dispositioning of test exceptions by the licensee.
Process parameter testing (see Paragraph 7.2) will also be reviewed.
3.2 (Closed) Followup Item (50-354/85-52-34) Develop procedures for shipping containers used under 10 CFR 71.12. This item is closed adminis-tratively since the licensee intends to utilize procedures from the Salem Nuclear Generating Station (SNGS) under an interface agreement between the two stations (Paragraph 5).
4.
Organization The organizational structure of the licensee's. Radiation Protection
/ Chemistry and Operations Departments was reviewed to determine if clear designations of responsibilities were provided for solid radwaste pro-cessing, packaging and shipping activities. Criteria provided in the licensee's Technical Specifications and FSAR were used in this review.
The organization was discussed with supervisory personnel from the two departments. The draft " Letter of Agreement" between Hope Creek Generat-ing Station (HCGS) and Salem Nuclear Generating Station (SNGS) governing radioactive materials shipments from Artificial Island was reviewed and discussed. A reorganization of the HCGS Radiation Protection Department (effective September 3, 1986) was also reviewed.
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Within the scope of this review, the following unresolved item was noted:
Technical Specification 6.2, " Organization," requires, in part, that the~
Hope Creek unit organization be as shown on Figure 6.2.2-1.
Figure
' 6.2.2-1 shows the Radiation Protection Engineer (RPE).in a supervisory role for the Radiation Protection Department (as Radiation Protection Manager or RPM) and the position Senior Radiation Protection Supervisor-Radioactive Materials Control'(RMC) supervising RMC Radiation Protection Supervisors.
In addition, the licensee's FSAR and Station Administrative Procedures describe the Radiation Protection Department organization as outlined in Figure 6.2.2-1.
Effective September 3,1986, Radiation Pro-tection Department Directive (RP-DD)-018 removed the RPE position from supervision of the department, abolished the Senior Radiation Protection Supervisor-RMC position and changed the responsibilities of the various Radiation Protection Supervisors (including the radwaste control, efflu-ents and shipping functions). When these differences were discussed with the licensee's representative, the licensee's representative indicated that appropriate changes to the Technical Specifications and F3AR would be requested.
Pending review of the licensee's requested changes to the organization of the Radiation Protection Department by NRC-NRR, the re-orgcnization under RP-DD-018 is unresolved.
50-354/86-44-01 5.
Procedures The licensee's procedures for preparation and classification of solid radwastes were reviewed relative to criteria provided in:
10 CFR 20.311, " Transfer for Disposal and Manifests;"
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Technical Specification S.8, " Procedures and Programs;"
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10 CFR 50, Appendix B, Criterion V, " Instructions,. Procedures and
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Drawings;" and NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements
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(Operation), " Revision 2 (February 1978).
Selected licensee procedures were reviewed and discussed with cognizant members of the licensee's staff.
The licensee had developed a contingency plan for processing solid rad-wastes using vendor-supplied solidification equipment temporarily attached to the plant radwaste system. Vendor operating procedures covering operations by two solidification service vendors were reviewed and dis-cussed with Operations personnel. The inspector noted that the procedures had been reviewed and incorporated as controlled plant procedures and included inspection hold points and other controls governing the vendor's process control programs.
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Procedures for classification and determination of radwaste acceptability for low-level waste burial were reviewed.
Under the draft letter of Agreement between the two stations, HCGS performs preliminary classifi-cation of solid radwastes and provides documentation to classify, mark, labei and manifest those radwastes. However, procedures implementing those aspects of the draft Letter of Agreement had not been developed by HCGS. At the exit interview on September 12, 1986, the inspectors stated that procedures regarding preliminary classification and provision of documentation sufficient to classify, mark, label and manifest solid radwastes provided by HCGS for shipment by SNGS would be reviewed during a subsequent inspection.
50-354/86-44-02 The inspectors noted that SNGS procedures included operating instructions for an accepted computer program used to classify solid radwaste shipments and that generic scaling factors for HCGS solid radwastes were included in the data base for that program.
Licensee personnel at HCGS iridicated that the generic scaling factors would updated as vendor analyses of radwaste streams were completed.
The licensee's procedures for sampling and analysis of radwaste streams and monitoring the Reactor Coolant System (RCS) were reviewed. The pro-cedures failed to provide administrative controls to evoke recharacteri-zation of waste streams if significantly increased activation or fission product activities were noted in the RCS.
The need for those adminis-trative controls was discussed with the licensee and provision of admin-1strative controls will be reviewed in a subsequent inspection. 50-354/
86-44-03 Under the dra't Letter of Agreement, radwaste shipmer.ts from HCGS will be shipped under existing SNGS procedures.
Procedures implementing activit-ies under 10 CFR 71.5 and 71.12 were reviewed at SNGS during previous inspections of that station, (e.g. combined Inspection Nos. 50-272/86-05; 50-311/86-05).
6.
Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a QA program for the packaging and transportation of radioactive materials. A Commission-approved QA program which satisfies the applicable criteria of 10 CFR 50, Appendix B and which is established, maintained and implemented with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.
The licensee elected to apply their established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radio-active materials.
In addition to the general QC elements required by 10 CFR 50, Appendix B, specific QC requirements under 10 CFR 20.311 are applicable to assure compliance with 10 CFR 61.55 and 61.56. A Commission-approved Process Control Program (PCP) for radwaste solidification is required by Technical Specification 6.13.
The licensee's Commission-approved PCP was acceptable for use in processing Class A radwastes only.
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The licensee's performance in establishing a QC program under 10 CFR 20.311 (d)(3) and Technical Specification 6.13 was determined by examina-tion for specific inspection hold points related to dewatering and com-pletion of solidification in vendor procedures. The development of a QC program related to the licensee's asphalt solidification process is dis-cussed in Paragraph 8.
The licensee appeared to have incorporated specific inspection hold points in vendor solidification procedures.
The site QC organization plans to provide inspections of packaging and shipping activities. However, the roles of the HCGS and SNGS QC organi-zations were unclear regarding which organization would provide inspec-tions of those packaging and shipping activities.
Under the draft Letter of Agreement, the HCGS QC organization would inspect packaging and ship-ping activities conducted at the HCGS and the SNGS QC organization would do likewise at SNGS. However, detailed inspection checklists for the HCGS QC organization had not been developed and the interfaces between the two QC organizations had not been defined. At the exit interview on September 12, 1986, the inspectors stated that QC fnspection procedures and interfaces would be reviewed in a subsequent inspection.
50-354/
86-44-04 The HCGS QA organization provides periodic surveillance of radwaste man-agement activities (including QC activities).
Current planning called for four quarterly surveillances per year as a minimum.
Procedures and check-lists were under development but awaited completion of the Letter of Agreement between HCGS and SNGS for definition of scope. At the exit interview on September 12, 1986, the inspectors stated that QA surveil-lance activities would be reviewed in a subsequent inspection.
50-354/
86-44-05 Audits of radwaste preparation, classification, packaging and shipping activities, vendor programs and training of radwaste personnel are con-ducted by the corporate QA organization. Annual audits of HCGS radwaste preparation, classification, packaging and shipping activities and train-ing were planned. Triennial vendor audits for packaging and radwaste disposal service vendors are planned. The inspectors noted that audit findings were to be evaluated by licensee management (as required by 10
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CFR 20.311(d)(3)).
7.
Solid Radwaste System The licensee's solid radwaste system was reviewed relative to commitments provided in the licensee's FSAR. Tours of the licensee's Radwaste Build-ing, observations of the radwaste equipment, review of system drawings and other documents and discussions with cognizant Engineering and Operations personnel were used to assess the status of the licensee's solid radwaste syste...
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l 7.1 Contingency Plan Review The licensee modified the solid radwaste system to provide permanent flanged connections to enable processing of concentrates, filter media, waste sludge and/or resin slurries by portable vendor-supplied dewatering / solidification systems. Three modifications providing the piping, valves, hangers and access to area were reviewed and dis-cussed with the licensee. The inspectors noted that modification safety reviews (including, ALARA reviews) were provided for each modification.
The licensee initially utilized manually-operated valves in the modification. A subsequent modification changed the valves to re-motely-operated valves. The third modification added tracks enabling larger cask liners to be used. An additional modification to add a return pipe is planned to improve processing capability (i.e. recir-culation).
The inspectors reviewed operation of the modified system during initial criticality and startup. Completed liners containing de-watered / solidified filter resins were surveyed for radiation by the inspectors. No liners had been shipped for burial.
Within the scope of this review, no problems were noted.
7.2 Asphalt Process The licensee's installed solidification / dewatering system utilizes high viscosity, oxidized petroleum-based asphalt of low residual volatile content and high molecular weight to firm a free-standing monolithic waste form. Completion of testing of this system was deferred from the preoperational period and was planned for comple-tion by mid-December 1986.
The inspectors reviewed the vendor's topical report on the asphalt system relative to the NRC's Technical Position on Waste Form. The licensee's plans for additional testing of the waste form to support an application for NRC approval to process Class B and C radwastes were also reviewed and discussed with cognizant Engineering and Operations personnel.
In addition to fulfilling the eight minimum requirements of 10 CFR 61.56(a), Class B and C wastes must fulfill the stability requirements of 10 CFR 61.56(b). The inspectors noted that four process variables were to be tested:
- asphalt type;
- waste chemical species being incorporated into the asphalt matrix;
- waste to asphalt ratios; and
- process temperatures.
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Completion of testing sufficient to establish proper process para-meter control will be reviewed under Followup Item No. 50-354/
85-44-10.
7.3 Dry Active Waste (DAW)
The licensee processes low-level dry radwastes in a hydraulically-operated box compactor. The control, monitoring, segregation, sort-ing and processing of DAW were discussed with Radiation Protection personnel. The licensee's tests showed approximately 5-6 fold volume reduction was being achieved by compactions.
However, the DAW box bulged at a compaction of approximately 40 pounds per cubic foot (about a 5 fold density increase).
Further testing and discussions with SNGS are planned to ensure that DAW boxes can be processed with-out bulging.
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Waste Generator Requirements Waste generator requirements under 10 CFR 20.311 and 10 CFR 61.55-56 were reviewed and discussed with the licensee. Disposal site license condit-ions were also discussed for disposal sites regulated by the States of Washington and South Carolina.
Since the licensee had not completed testing of the asphalt process and had not shipped solidified /dewatered radwastes from vendor processes, planning and preparations were reviewed.
8.1 Waste Manifests 10 CFR 20,311(d)(4) requires the licensee (as a radwaste generator)
to prepare shipping manifests meeting the requirements provided in 10 CFR 20.311 (b) and (c). Under the draft Letter of Agreement, HCGS would provide documentation sufficient to properly manifest the radwaste in a format specified by SNGS.
SNGS' procedures for pre-paring shipping manifests were reviewed and appeared to be adequate.
8.2 Waste Shipment Labeling 10 CFR 20.311(d)(2) requires the licensee (as a radwaste generator)
to label each radwaste package to identify its waste class under 10 CFR 61.55. Under the draft Letter of Agreement, HCGS would provide documentation sufficient to properly label the radwaste and SNGS would label the package. SNGS' procedures for labeling radwaste shipments were reviewed and appeared to be adequate.
8.3 Waste Shipment Tracking Under 10 CFR 20.311(d), (e), (f) and (h), the licensee (as a radwaste shipper) must track each radwaste shipment from the licensee's facil-ity to the land disposal facility to ensure its timely receipt by the disposal facility. The draft Letter of Agreement calls for perfor-mance of all " external communications" by SNGS.
SNGS' procedures for tracking radwaste shipments were reviewed and appeared to be accep-tabl _ _ _ _ _ _
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m 8.4 Waste Classification 10 CFR 20.311(d)(1) requires, in part, radwaste classification ac-cording to 10 CFR 61.55. The draft Letter of Agreement calls for preliminary classification by HCGS to properly select radwaste con-tainers and actual classification by SNGS personnel using the RADMAN computer program. The licensee developed generic sealing factors based on industry startup averages and radwaste stream data from Susquehanna station. Those scaling factors were entered on the hard disc for the SNGS IBM PC used to execute the RADMAN program of SNGS.
On September 11, 1986, the inspectors checked the disc-recorded data against the scaling factors recorded in the licensee's description report for 2 of HCGS radwaste streams and checked several test runs for resins and powder filters by hand calculations based on an ex-ternal dose rate from the liner of 1 millirem per hour. The results of those calculations checks showed that the computer program se-lected and used the appropriate scaling factor from the HCGS data in calculating the activities due to "hard to identify" radioisotopes.
The program appeared to properly classify the hypothetical radwaste shipment in each instance.
8.5 Waste Form and Characterization
10 CFR 20.311(d)(1) requires, in part, that licensees prepare rad-wastes to meet the waste characteristics requirements of 10 CFR 61.56.
In addition to fulfilling the eight minimum requirements of 10 CFR 61.56(a), Class B and Class C waste must also fulfill the j
stability requirements of 10 CFR 61.56(b). The inspectors reviewed
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the asphalt solidification vendor's topical report, the preopera-tional test program and the performance test program to determine if the licensee had planned a test program to determine if the licensee had planned a test program sufficient to determine the process para-meters needed to provide a waste form meeting 10 CFR 61.56(b) re-quirements for Class B and Class C radwastes solidified in asphalt.
The vendor's topical report indicated that the asphalt product from the crystallizer (regenerative evaporator bottoms) containing 16.92%
sodium sulphate (by dry weight) failed the immersion test when in-corporated into the asphalt at 30% (by dry weight).
Following immersion, the asphalt formed with this test mixture failed the com-pression test (as a probable result of crystalling swelling of the sodium sulfate when exposed to water). Thus, the asphalt product containing 5% sodium sulfate did not form a radwaste product making the compression test following immersion (vis. 16.92% x 30% = 5.08%
sodium sulphate). The licensee indicated that regenerative wastes may not be processed by the asphalt solidification and consideration was being given to nonregeneration of resins.
The vendor's topical report indicated that the asphalt product cannot incorporate more than 1% oil. The licensee indicated that oils will
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be solidified by other methods (e.g. cement) and administrative con-
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trols will be used to limit the introduction of oils into the waste streams processed through the extruder-evaporators.
i Review of the licensee's test program indicated that:
- extruder / evaporator temperature profiles would be established;
- weight ratios of waste to asphalt would be determined for each waste stream; and
- specification for asphalt would be verified (i.e. ASTM D 312-71, Type 3 specifications).
The inspectors noted that maximum achievable loading of waste was characterized by an increase in product viscosity to the point where the molten asphalt waste mix product became grainy and was no longer fluid when discharged from the extruder.
Based on experience at Palisades, temperature profiles and order of addition of molten asphalt to the 55 gallon drums are important to minimize the formation of void spaces above tha solidified asphalt-waste product. The licensee indicated that performance tests on drum loading would be performed to ensure minimization of void space in the drums on solidification.
8.6 Process Control Program Following completion of testing on the asphalt process, the licensee will have established site-specific process parameters needed to ensure the production of a suitable waste form for low-level waste burial. However, those parameters must be incorporated into system operating procedures with appropriate inspection hold points and other quality control activities to ensure that the waste form is controlled from waste batch to waste batch. At the exit interview on September 12, 1986, the inspectors stated that development and im-plementation of a site-specific process control program for the asphalt process would be reviewed during a subsequent inspection.
50-354/86-44-06 8.7 Disposal Site License Conditions Since the licensee had not made radwaste shipments to either waste burial site, compliance with waste burial site license conditions could not be determined.
If radwaste shipments are made under exist-ing SNGS procedures, previous inspections have shown that those pro-cedures address disposal site licensee conditions. The inspectors noted that Amendment 43 to South Carolina Radioactive Material Lic-ense No. 97 for the Barnwell site authorized Chem-Nuclear Systems to accept solidified asphalt radwaste materials provided that waste was a free-standing monolith and did not demonstrate characteristics of a free-flowing, viscous liquid.
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Packaging / Shipping Under 10 CFR 71.5, a licensee delivering licensed material to a carrier for transport is required to comply with the applicable requirements of the Department of Transportation in 49 CFR Parts 170 through 189. Under 10 CFR 71.12, the use of transport packages for which a license, certifi-cate of compliance or other approval has been issued by the NRC is permit-ted provided the licensee meets the conditions of 10 CFR 71.12. Under the draft letter of Agreement, implementation of these requirements would be the responsibility of SNGS. Previous inspections of SNGS have shown their procedures in these areas'to be generally adequate.
Since radwaste ship-ments had not been made by HCGS, review of this area was postponed until a subsequent inspection.
10. Exit Interview The inspector met with the licensee's representatives (denoted in Para-graph 1) at the conclusion of the inspection on September 12, 1986.
During the meeting, the inspectors summarized the purpose and scope of the inspection and identified findings as described in this report.
At no time during this inspection was written material provided to the licensee by the inspectors. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.
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