IR 05000387/1988005
| ML17156A407 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/22/1988 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156A405 | List: |
| References | |
| 50-387-88-05, 50-387-88-5, 50-388-88-04, 50-388-88-4, NUDOCS 8802290399 | |
| Download: ML17156A407 (12) | |
Text
U.S.
NUCLEAR'EGULATORY COMMISSION
REGION I
Report Nos.
50-387/88-05 50-388/88-04 Docket Nos.
50-387 50-388 License No.
NPF-14 NPF-22 Priority Category C
Licensee:
Penns lvania Power 5 Li ht Com an 2 North Ninth Street A
entown, Penns vani a 18101 Facility Name:
Sus uehanna Steam Electric Station Inspection At:
Herwick, Penns lvania Inspection Conducted:
Januar 25-29, 1988
& ~
Inspectors:
H. J.
Bscehous iatson Specia ist Approved by:
~ A c
. J.
scca, seT Eff nts Radiation Protection Section z/2i/es ate Ins ection Summar
Ins ection on Januar 25-29 1988 Com bined Re ort Nos.
- 87 88-05 an 50-388 88-04 Areas Ins ected:
Routine, unannounced safety inspection of the licensee's so s
ra ioact~ve waste (radwaste)
processing and preparation and radioactive materials packaging and shipping programs including previously identified items, management controls, quality assurance/quality control, radiochemistry, solid radwaste processing, radwaste generator requirements and radioactive materials shipping requirements.
Messrs.
A. Grella (NRC) and S. Maingi (PA DER) accompanied the inspector during portions of the review.
Results:
No violations or deviations were identified.
The licensee was
~gamp ementing effective programs in the areas reviewed.
88022K 03~9 5000387 880225 PDR ADOCK 0 PDR
Details Persons Contacted 1. 1 Licensee Personnel G. Appel, Radiochemist
- J. Blakeslee, Jr., Assistant Plant Superintendent
- A. Dominque, Operations
- J. Folta, Quality Assurance/Quality, Control
- J. Fritzen, Radiological Operations Supervisor
- D. Hoffelfinger, Quality Assurance/Quality Control J. Hettinger, Quality Assurance/Quality Control K. Mattern, Operations Radwaste Engineer
- D. McGann, Compliance Engineer
- A. Nargoski, Quality Assurance/Quality Control
- R. Prego, Ouality Assurance Supervisor - Operations D. Rarick, Ouality Control Inspector K. Rousch, Nuclear. Training
- R. Stigers, Nuclear Support
- S. Strelecki, Health Physics Other licensee personnel were also contacted or interviewed.
1.2 Penns lvania De artment of Environmental Resources (PA DER)
- S. Maingi, Nuclear Engineer 1.3 NRC Personnel A. Grella, NMSS Transportation Specialist J. Stair, Resident Inspector
- Attended the exit interview on January 29, 1988 2.
~Sco e
This routine safety inspection reviewed the licensee's solid radioactive waste (radwaste)
processing and preparation and radioactive materials packaging and shipping programs (as implemented by the licensee)
from August 29, 1986 through January 29, 1988.
During that period, the licensee made approximately 270 shipments of solid radwaste and other radioactive materials.
A sample of 16 shipments was selected and reviewed relative to requirements in 10 CFR 20.311,
CFR 61.55-56,
CFR 71,
CFR 170-189 and the licensee's technical specifications.
In addition, solid radwaste processing and preparation facilities and equip-ment were reviewed.
3.
Previousl Identified Items
3.1 3.2 (Closed)
Follow-up Item (50-387/84-25-05; 50-388/89-32-03);
Review laboratory gA/gC program The licensee had issued a chemistry procedure (CH-gC-002) which formalized the interlaboratory quality assurance/quality control (gA/gC) program and had implemented that procedure.
This item is closed.
(Cl osed)
Fol 1 ow-up Item (50-387/86-17-01; 50-388/86-18-01):
Improve charcoal cartridge counting procedures and minimum total counts in gamma spectroscopy calibrations.
The licensee had issued and implemented a change to a calibration procedure (CH-IC-004) to require a minimum of 20,000 counts for each peak used for calibration of gamma spectroscopic equipment.
The licensee had also issued and implemented a change to the iodine cartridge counting procedure (CH-RC-039) providing directions for placement of charcoal cartridges on the detector.
This item is closed.
,
3.3 Manaqement Controls (Closed)
Follow-Up Item (50-387/86-17-02; 50-388/86-18-02):
Review OC control charts regarding actions on warning limits and control limits.
The licensee initiated a program to monitor changes in detector efficiency in April 1987, evaluated data from that program and developed a procedure to formalize actions to be taken when warning or control limits are exceeded (CH-TP-024).
This item is closed.
4.1 Oraanization The organizational structure of the licensee's solid radwaste processing and preparation and radioactive materials packaging and shipping activities were reviewed relative to Final Safet Anal sis Re ort FSAR commitments and technical speci
~cation requ rements.
versight of contractor dewatering and solidification services was also reviewed (NRC IE Information Notice No. 87-07).
Solid Radwaste operations are the responsibilities of the Radwaste Operations Engineer (Operations Department)
including oversight of contracted dewatering and solidification services.
Operations personnel transfer and process the various solid radwaste streams providing a prepared liner or high integrity container with dewatered/solidified resins, filters and/or sludges suitable for shipment.
Dry active waste is collected, shredded and compacted under Health Physics supervision.
Health Physics also has responsibility for packaging and shipping all radioactive materials (including, but not limited to solid radwaste).
The Chemistry Group provides sampling and analyses necessary to characterize the waste streams under
CFR 61.55 and performs test solidifications under the licensee's Process Control Program (PCP).
The guality Control (gC) Group inspects the process controls, liners, high integrity containers, packages and shipping activities through procedurally based "hold" or inspection points.
The inspector noted
that authorities and responsibilities were well-defined and understood by individuals within the groups, interfaces were fully functioning and oversight of contracted solidification/dewatering activities were well-established and functioning.
No problems were noted.
4.2 Procedures The licensee's administrative and selected operating procedures governing processing and preparation of solid radwaste materials and packaging and shipping of radioactive materials were reviewed relative to criteria in 10 CFR 20.311,
CFR 61.55-66,
CFR 71.5,
CFR 71.12 and the licensee's technical specifications.
The following procedures were reviewed, discussed with the licensee and checked for implementation AD-QA-311, "Solid Radioactive Waste Process Control Program",
Revision 8 (December 22, 1987);
AD-QA-323, "Radioactive Waste Drum Tracking, Revision
(October 28, 1987);
AD-OA-765, "Solid Radwaste Program," Revision ll (December 11, 1987);
'P-TP-800,
"Shipment of Radioactive Waste Material," Revision
(March 24, 1987);
HP-TP-801,
"General Shipment Of Radioactive Material," Revision 6, (October 30, 1986);
and HP-TP-851,
"Rad Waste Curie Calculations, Revision 5, (November 4, 1986).
Within the scope of this review, no violations were noted.
However, the following weaknesses were noted and discussed with the licensee:
The licensee's procedures did not provide for independent veri-fication of radiation/contamination measurements for shipments.
Although QC personnel witnessed the measurements, QC did not include verification of those measurements with additional radiation detection instrumentation and/or wipe tests.
The licensee used a tedious method of hand calculations completed by health physics technicians to determine waste classifications under
CFR 61.55 and appropriate shipping containers under
CFR 71.
Although supervisory review of the calculations was commonly done, procedures did not require supervisory verifica-tio At the exit interview on January 29, 1988, the licensee representative indicated that these apparent weaknesses would be reviewed and resolved.
4.3 Indoctrination and Trainin In response to NRC IE Bulletin No. 79-19, the licensee committed to periodic retraining of personnel assigned to radwaste packaging
'and shipping activities.
Discussions with Operations Health Physics and guality Control personnel indicated that each had completed an inhouse training course, (i.e. HP-043,
"Radwaste Worker Training,"),
and key individuals had received offsite training at Barnwell, South Carolina.
No deviations from licensee commitments were noted in this brief review.
4.4 Self-Identification/Correction of Deficiencies Under the licensee's Significant Operating Occurrence Report (SOOR)
program unusual occurrences are identified, tracked, closed and trended.
Eight Significant Operating Occurrence Reports involving solid radwaste processing problems were reviewed to determine what corrective actions were taken and when those actions were or would be completed.
Within the scope of this review, no violations were noted.
The licensee had used the SOOR program to identify and correct solid radwaste processing deficiencies in a comprehensive and timely manner for the eight reports reviewed.
5.
Oualit Assurance/ ualit Control OA/
C Specific quality control requirements are mandated by 10 CFR 20.311 to assure compliance with 10 CFR 61.55-56.
The establishment of a quality assurance program for the packaging and transportation of radioactive materials is required by 10 CFR 71, Subpart H.
A Commission-approved guality Assurance Program which satisfies the applicable criteria of 10 CFR 50, Appendix B, and which is established, maintained and implemented for transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.
Guidance regarding applicable criteria for a quality assurance program for transport packages was provided in NRC IE Information Notice No. 84-50.
The licensee elected to apply the established
CFR 50, Appendix B, Ouality Assurance Program to packaging and shipping activities.
The application of the licensee s
quality assurance/quality control program to the licensee's responsibilities as a solid radwaste generator and radioactive materials shipper was reviewed.
5. 1 Waste Generator OC/Process Control Pro ram Licensee's procedures were reviewed to determine if appropriate quality control checks were included to ensure proper classification of radwaste shipments under
CFR 61.55 and proper radwaste form under
CFR 61.56.
Of the sixteen shipments reviewed, fourteen involved solid radwastes.
For those shipments, implementation of
procedural holdpoints, verification of test samples for solidifica-tions and other quality control verifications (such as final checks of hardness and/or dewatering)
were reviewed.
Audit No.86-086,
"Solid Radioactive Waste Program,"
(completed December 23, 1986)
was reviewed to determine its inclusion of attributes related to 10 CFR 61.55-56 compliance, process control program implementation, licensee management review of that audit and resolution of findings and recom-mendations.
(The 1987 annual audit was incomplete at the time of the review).
Appropriate inspection holdpoints had been included and implemented by quality control personnel suitably knowledgeable.
Audit No.86-086 adequately covered attributes of 10 CFR 61.55-56, the process control program and had received appropriate licensee management review and resolution of findings.
Within the scope of this review, no violations were noted.
The licensee was implementing an effective quality control program under
CFR 20.311.
5.2 Radioactive Haterials Shi er A/
C Licensee's procedures were reviewed to determine quality control attributes verified in receipt and shipping inspections of transport packages.
Implementation of those procedures was verified for the sixteen radioactive materials shipments.
Shipping records were also reviewed to verify quality control inspection of applicable items of the packaging's Certificate of Compliance under
CFR 71. 12.
Surveillance activities for procedural adherence were conducted by the licensee's gA personnel.
Audit No.86-086 was reviewed for inclusion of attributes needed to ensure compliance with 10 CFR 71.
The inspector noted that the audit team members were technically qualified in radioactive materials shipping and solid radwaste generation requirements.
hithin the scope of this review, no violations were noted.
The licensee was implementing a gA/gC program in reasonable agreement with guidance provided in NRC IE Information Notice No. 84-50.
6.
~Rdi h
The "Low-Level Waste Licensing Branch Technical Position on Radioactive Waste Classification,"
(Hay, 1983, Revision 0), suggests an acceptable sampling and analysis program for power reactors to meet
CFR 61.55 Waste Classification requirements for hard-to-identify radionuclides and allows the use of scaling or correlating factors to gamma-emitting radionuclides.
The inspector reviewed licensee fuel performance and reactor coolant system radioactivities to determine the general adequacy of the licensee's sampling, and vendor analysis program for hard-to-identify radionuclides.
The licensee was generating only Class A
radwastes with a suggested minimum sampling and analysis interval of every two years provided that none of the conditions below were observed:
e
(1)
substantial changes in fission-product concentrations in the reactor coolant (e.g. fuel failure);
(2)
substantial increases in activation or corrosion product concentrations in the reactor coolant (e.g.
resuspension of solids in the system);
(3)
Increases in both fission and activation product concentrations; and/or (4)
Radwaste equipment or processes were put into service for which no radiochemical data (and correlating factors)
were available.
Unit 1 and 2 steam jet air ejector (SJAE) offgas radiation monitor data and reactor coolant system gross and, gamma spectroscopic data for 1985-1987 were reviewed in summary form.
An increase in Unit 2's offgas release rate of approximately five fold was noted in late 1987 suggesting minor fuel failure.
(The rate of release was less than 15 of technical specification limits).
Total cobalt-60 in Unit 2 reactor water also increased about ten-fold suggesting an activation/corrosion product release into the cool-ant earlier in 1987.
Review of the licensee's actual sampling program showed that radwaste streams were routinely sampled every six months and analyzed.
The licensee's sampling and analysis program was adequate for present conditions.
Solid Radwaste Processin
/Pre aration The licensee collects, shreds and compacts dry active waste materials.
Filter-deionizer and bead resins are collected in tanks in the Radwaste Building and either dewatered or solidified in a vendor-supplied process.
Installed solid radwaste equipment originally included in the design for dewatering/solidification is not currently used.
The inspector reviewed operations of each of these radwaste systems against previous licensee commitments, ANSI/ANS 55.1-1979, American National Standard for Solid Radioactive Waste Processing System for Light Water Cooled Reactor Plants, and
CFR 20.
Systems review included routine mixing and transfer of resins, sorting and segregation of hazardous'astes, shreddino/compacting and ventilation controls.
The interface between the plant resin transfer capabilities and the vendor-supplied dewatering/solidification equipment was reviewed to assess potential operating problems including spills, rupture of transfer hoses and "dead-heading" or cavitation of slurry pumps.
Within the scope of this review, no problems were noted.
Operating procedures were adequate to prevent overpressurization of transfer hoses and other common problems.
Radwaste Generator Re uirements The inspector reviewed fourteen radwaste shipments made by the licensee against each of the following radwaste generator requirements:
Waste Manifests under
CFR 20.311(d)(4)
and 20.311(b)
and (c);
Waste Classification under
CFR 20.311(d)(3)
and
CFR 61.55; Waste Form and Characterization undet
CFR 20.311(d)(3)
and
CFR 61.56; Waste shipment labeling under
CFR 20.311(d)(2)
and
CFR 61.55; Tracking of waste shipments under.
CFR 20.311(d),(e),(f)
and (h); and Adherence to disposal site license conditions for Agreement State licenses under
CFR 30.41.
The basis for determination of waste class, (e.g.
sampling, vendor analyses, correlation factors for hard-to-identify radionuclides and calculations)
was also reviewed for each shipment relative to the guidance provided by the Branch Technical Position.
Within the scope of this review, no violations were noted.
Good technical bases were noted for the Class A routine shipments.
The licensee had taken appropriate samples at more frequent intervals than required, updated correlation factors using accepted methods and implemented the classification program consistent with regulatory guidance.
Adequate quality control of waste form was also evident.
9.
Radioactive Materials Shi in Re uirements The sixteen shipments, (i.e. fourteen radwaste and two other radioactive materials shipments to other licensees),
were reviewed relative to criteria contained in 10 CFR 71 and
CFR 170-189 to determine if transportation requirements had been met.
9. 1 Procurement and Selection of Packa es The selection of packages for each shipment was reviewed relative to requirements in 49 CFR 173 and
CFR 71.12.
Specifications provided in procurement documents were also briefly reviewed.
Performance relative to the criteria was determined by review of procedures, procurement documents and radioactive shipping records, discussions with licensee personnel and direct observation of a shipment in progress.
Within the scope of this review, no violations were identified.
9.2 Pre aration of Packa es'for Shi ment The licensee's preparation of "strong-tight" and specification packages for shipment was reviewed relative to requirements in
CFR 172 and 173,
CFR 71.87 and licensee's procedures Nos.
HP-TP-800 and HP-TP-801.
Shipping cask preparations were reviewed relative to 10 CFR 71. 12 and individual Certificates of Compliance and accompanying documents.
Performance relative to the criteria was determined by interviews of licensee personnel and review of radioactive shipping records.
No violations were noted within the scope of the revie.3 Deliver of Packa es to Carriers The delivery of packages to transport carriers was reviewed relative to placarding, shipping manifests and public highway shipping requirements in 49 CFR 177.
Actions taken to ensure proper blocking, bracing and securing radioactive materials packages, (NRC Information Notice No. 87-31), were also reviewed.
Discussions with licensee personnel, review of shipping records and examination of photographs of licensee shipments were used to determine the licensee's performance relative to these criteria.
Within the scope of this review, no violations were identified.
9.4 Incidents No warnings or violations were issued by Agreement States to the licensee during the period covered hy this inspection.
10.
Exit Interview The inspector met with the licensee's representatives denoted in Detail (1) at the conclusion of the inspection on January 29, 1988.
The inspector summarized the scope and findings of the inspection as described in this report.
The inspector also summarized regulatory problems noted with shipment of rental shearing equipment, control rod blades and low power range monitor probes since the licensee was considering future disposal of control rod blades and LPRMs.
At no time during the inspection was written material provided to the licensee by the inspector.
No information exempt from disclosure under
CFR 2.790 is discussed in this report.