IR 05000387/1994024
| ML17164A510 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/21/1994 |
| From: | Bores R, Eckert L, Randolph Ragland NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17164A508 | List: |
| References | |
| 50-387-94-24, 50-388-94-25, NUDOCS 9501110034 | |
| Download: ML17164A510 (18) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Inspection Nos.
50-387/94-24; 50-388/94-25 Docket Nos.
50-387; 50-388 License Nos.
Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Susquehanna Steam Electric Station, Units 1 5 2 Inspection At:
Berwick, Pennsylvania Inspection Conducted:
October 31 - November 4, 1994 Inspector:
Inspector:
Approved by:
R.
C.
Rag nd, r., Radiation pecialist I
L.
Ec rt, Radi ati on peci al ist l>l<< lg Dr.
R. J.
Bores, Chief Facilities Radiation Protection Section Areas Inspected:
Announced inspection of the radiation protection program at the Susquehanna Steam Electric Station (SSES).
The inspection principally focused on solid radwaste management, transportation of radioactive material, and management of low-level radwaste storage facilities.
This included a
review of audits and appraisals; changes to organization, personnel, and facilities; training and qualifications of personnel; implementation of the solid radwaste program; characterization and classification of wastes; shipping for disposal and transportation of other materials; safety reviews for the low-level radwaste holding facility (LLRWHF); start-up and operations of the LLRWHF; and LLRWHF liquid effluent monitoring.
Results:
There was overall good performance which included effective implementation of the solid radwaste management and transportation of radioactive material program and effective management of the low level radwaste holding facility.
The system for performing audits and surveillances, identifying deficiencies, and communicating findings, resulting in corrective actions was good.
However, a concern was noted relative to the adequacy of past corrective actions for audit findings, although no current problem was identified (Details paragraph 3.0).
Significant personnel changes have been made within the effluents management and these changes were made in a commendable manner.
Implementation of the solid radwaste program, 9501110034 941222 PDR ADOCK 05000387
characterization and classification of wastes, and shipping for disposal and transportation of radioactive materials was good.
Supporting calculations for the LLRWHF safety review were excellent, and general operation of the LLRWHF was good.
Training and qualification weaknesses were identified with respect to hazardous materials training for Radwaste Shipping technicians and quality assurance personnel (Details paragraphs 5.2. 1 and 5.3).
One apparent violation involving a failure to provide certification that individuals responsible for certifying the adequacy of radioactive material shipments had received proper training was identified (Details paragraph 5.4).
INDIVIDUALS CONTACTED DETAILS 1.2 PRINCIPAL LICENSEE EMPLOYEES T. Dalpiaz, Manager, Nuclear Maintenance
- S. DiPippa, Senior guality Control Specialist
- J. Finnegan, Nuclear Compliance Supervisor
- D. Hagan, Health Physics Supervisor
- J. Hettinger, Effluents Management Supervisor
- G. Kuczynski, Nuclear'Plant Services Manager P. Jaeger, Supervisor, Effluents Management
- C. Lewis, Health Physicist, Effluents Management
- J. Lex, Training Supervisor
- W. Morrissey, Health Physics Supervisor
- R. Prego, Supervisor, Site guality.Verification
- M. Sawicki, Power Production Engineer G. Stanley, Vice President, Nuclear Operations
- R. Wehry, Nuclear Compliance NRC EMPLOYEES
- D. Mannai, Resident Inspector Denotes attendance at the exit meeting on November 4, 1994.
The inspectors were accompanied during part of this inspection by David Ney of the Pennsylvania Department of Environmental Resources (PADER).
The inspectors also contacted other licensee personnel during the course of the inspection.
2.0 PURPOSE AND FUNCTIONAL AREAS INSPECTED The inspection was conducted to review the solid radwaste management and transportation of radioactive materials programs, and management of low-level radwaste storage facilities.
This included a review of the following.
audits and appraisals changes to organization, personnel, and facilities training and qualifications of personnel implementation of the solid radwaste program characterization and classification of wastes shipping for disposal and transportation of other materials safety reviews for the low-level radwaste holding facility (LLRWHF)
start-up and operations of the LLRWHF, and LLRWHF liquid effluent monitoring
3.0 AUDITS AND APPRAISALS The inspectors performed a review of the performance of audits and appraisals for radwaste management and transportation of radioactive materials.
The review included an evaluation to determine the following.
If audits were being performed to meet applicable plant Technical Specification requirements and federal requirements identified in
CFR 20,
CFR 61, and
CFR 71 If audits were being performed in accordance with station procedures If audits included program assessments If problems requiring corrective action were being identified If corrective actions were being implemented as a result of audit findings, and If corrective actions were effective in preventing recurrence of identified problems The evaluation of the licensee's performance was based on a review of guality Assurance audits, surveillance reports, procedures, and other documents, and discussions and interviews with various members of the guality Assurance and Effluents Hanagement organizations.
The inspectors found that audits of the Radiological Environmental Honitoring Program and Process Control Program were performed in accordance with Technical Specifications requirements.
The inspectors reviewed the following guality Assurance reviews.
Audit ¹93-141,
"SSES NgA/SRC Audit of Effluent Release and Solid Radioactive Waste Process Control Program,"
12/14/93.
Audit ¹91-110,
"SSES NgA/SRC Audit of Effluent Release and Solid Radioactive Waste Process Control Program,"
12/14/91.
SSES N(A/SRC Audit Finding Closeout for Audit ¹91-110,
"Effluent Release and Solid Radioactive Waste Process Control Program,"
12/14/91.
SSES guality Assurance Surveillance Report No.94-094,
"Contaminated Laundry Shipment ¹93-100,"
10/29/93.
SSES guality Assurance Surveillance Report No.94-038,
"Decon Technician Certification DAW Sorting," 6/9/94.
SSES guality Assurance Surveillance Report No.93-117,
"Transfer and Drying of Powdered Resin," 1/31/94.
SSES guality Assurance Surveillance Report No.94-043,
"Irradiated Jet Pump Beam and Shroud Head Bolt Transfer,"
10/24/94.
SSES guality Assurance Surveillance Report No.94-037,
" Irradiated Jet Pump Beam Disposal," 7/25/94.
The inspectors found that audits and surveillances were being performed in accordance with applicable procedures, program assessments were performed and problems requiring corrective actions were being identified and reported to the Effluents Hanagement group and to
4.0 appropriate levels of station management.
Documentation also revealed that corrective actions were being implemented as a result of audit findings.
In general, corrective actions implemented as a result of guality Assurance findings adequately addressed identified problems.
However, licensee findings noted that NgA/SRC Audit ¹93-141, issued on 12/14/93, identified the same three findings that were previously identified in NgA/SRC Audit ¹91-110, issued on 12/14/91.
Each of the findings involved personnel failure to implement procedurally established requirements.
Although, in each case, the safety significance was low, this raised the concern to the inspectors that identified corrective actions may not be sufficiently broad scope to prevent recurrence.
The inspectors reviewed the corrective actions that were initiated as a result of Audit ¹93-141 to determine if a current problem existed.
The inspectors found that the corrective actions addressed the problem in a generic manner.
The inspectors then reviewed the corrective actions that were initiated as a result of audit ¹91-110.
The inspectors found that the corrective actions that were implemented, addressed only the specific occurrence.
While it does not appear that a
cur rent problem exists with the identification of corrective actions in response to audit findings, additional management attention may be necessary to ensure that corrective actions generated from audit findings are reviewed from a generic perspective.
The adequacy of corrective actions resulting from audit findings will be reviewed during future inspections.
No safety concerns or violations of NRC requirements were identified.
CHANGES TO PERSONNEL AND ORGANIZATION The inspectors performed a review of major changes in personnel, organization, facilities, equipment, programs, and procedures that may have affected waste management and transportation of radioactive materials.
4.1 PERSONNEL The inspectors were informed that Hr. James R. Doxsey was named Supervisor of Effluents Management in March 1994.
The Effluents Management Supervisor is responsible for the management of radioactive and non-radioactive wastes, environmental compliance, decontamination and support services, and the transportation and shipment of radioactive materials and wastes.
Six first line supervisors or project specialists report directly to the Effluents Management Supervisor.
The inspectors compared Hr. Doxsey's qualifications to the qualification requirements identified in Susquehanna Steam Electric Station's (SSES)
plant Technical Specifications and final safety analysis report (FSAR).
These documents require the Supervisor of Effluents Management to meet or exceed the qualification requirements listed in American National Standard ANSI N18. 1.
Mr. Doxsey has 19 years of nuclear experience including experience as a supervisor of Reactor Engineering, Shift Technical Advisor, Senior Reactor Operator, Plant Engineering
4.2 Supervisor, and Simulator Instructor for Licensed Operator training.
Although Hr. Doxsey has no direct background or experience in radwaste transportation, he has ready access to a well qualified staff, and he brings a broad range of plant systems knowledge to.the organization.
Consequently, Hr. Doxsey has been determined to meet the qualification requirements for the position of Supervisor of Effluents Management.
The inspectors were also notified that 33 individuals were recently hired into the Effluents Management organization to fill positions with the title "Handyman Helper".
Individuals assigned as Handyman-Helpers are responsible for, among other matters, decontamination of tools, equipment, and facilities; transporting lead shielding; and handling radwaste packages.
Previously, these positions were held by vendor personnel.
In addition to the Handyman-Helper positions, six individuals have been hired from within the company into positions as Assistant Foreman.
This presented challenges for the Effluents Hanagement organization and the Nuclear Training Department to ensure effective management of human resources during the transitional period.
Job descriptions had to be written and a training and qualification program had to be developed and implemented.
Also, additional changes to job descriptions and the training and qualification process are planned.
Although anticipated problems were encountered during the transition, no significant impacts or degradation in performance have been identified.
This performance has been noted as commendable.
The inspectors were also informed that company goals for downsizing are being developed.
However, no significant impacts are expected on the Effluents Nanagement organization.
No deficiencies or violations of NRC requirements were identified.
ORGANIZATION The inspectors reviewed the current organization char t for Effluents Management dated August I, 1994.
The inspectors were notified that the organization charts did not reflect recent changes made to the organization.
The Radwaste Supervisor Decon Support had been temporarily reassigned to a special project to head a station effort for radwaste volume reduction.
Responsibilities for Decon Support, including supervision of additional Handyman-Helpers, were transferred to the Foreman-Health Physics, Rad Haterial Control.
t As a result of these changes, no impact on performance has been identified.
5.0 TRAINING AND UALIFICATION OF PERSONNEL The inspectors reviewed licensee training and qualification programs for individuals responsible for processing, testing, storage, classification and shipping of low level radioactive waste and other radioactive materials.
This included individuals assigned general tasks in radwaste, Health Physics Technicians, Quality Assurance/Quality Control
Inspectors, and individuals responsible for certifying the adequacy of radioactive waste shipments.
The inspectors reviewed the following training and qualification documents.
5.1 Nuclear Training Procedure NTP-(A-42.6, "Effluents Management Training and Certification," Rev.
Nuclear Training Curriculum, Effluents Management, Approval Date 7/20/94, form NTP-(A-11.2C.
Rev.
Radwaste Worker Training, HP043, Rev.
4, 12/7/93 General Employee Retraining, GETOIR, Rev. 32, 9/7/94 Health Physics Level II Training, HP002, Rev. 4, 8/24/94 Health Physics Level II Retraining, HP002R, Rev.
2, 5/25/94 The training and certification program for Effluents Management personnel is described in NTP-(A-42.6, Effluent Management Training and Certification Program and course requirements are documented in the Training Matrix for Effluents Management Personnel, Form NTP-gA-11.2A.
EFFLUENTS MANAGEMENT PERSONNEL All Effluents Management personnel are responsible for completing HP043,
"Radwaste Worker Training," prior to performing tasks in support of radwaste duties and every two years thereafter in order to maintain qualification.
This course provides information on purpose of training, regulations, current disposal options, process control program, liquid waste processing, dewatering, dry active waste, sorti.ng clean wastes, hazardous material communications, station events, and programs for error minimization.
5.2 The inspectors noted that this training satisfies training requirements specified in 49 CFR 172 Subpart H for general awareness and safety training.
The inspectors also noted that this training provided a good overview of processes used for collection, processing, packaging, transportation, and disposal of radioactive wastes and marking and labeling used to identify hazardous materials.
No deficiencies or violations of NRC requirements were identified.
HEALTH PHYSICS TECHNICIANS The inspectors reviewed training provided to Health Physics Technicians assigned to the Effluents Management organization.
All of the Health Physics (HP) technicians assigned to the Effluents Management organization are responsible for attending HP043
"Radwaste Worker Training."
As noted above, this training provided a good overview of radioactive waste for individuals assigned to Effluents Managemen Radwaste Shi in Technicians Selected Health Physics Technicians are assigned as radwaste Shipping Technicians.
These individuals, while under supervision by trained and qualified personnel, are responsible for preparing radioactive material shipments and shipping papers.
However, these individuals are not designated responsibility for certifying the adequacy of radioactive material shipments.
These individuals do receive additional training.
Shipping Technicians were provided a course entitled
"Development of Scaling Factors for Low-Level Waste Characterization" and training on a
computer code used to classify radioactive material shipments and to prepare shipping papers (RADMAN).
The inspectors were informed that once technicians gain experience in radwaste transportation (i.e.,
a year or two of experience),
these individuals are provided the training course entitled HP-1001,
"Radwaste,Shipping Qualification."
Although the inspectors characterized the training provided to Shipping Technicians as good, two weaknesses were identified.
1)
The procedur alized training curriculum for Effluents Management personnel specifies that only selected Shipping Technicians are required to receive the Radwaste Shipping Qualification course.
Because the potential exists that an individual with limited training could perform a significant portion of work associated with the preparation of radioactive material shipments, this was noted as a weakness.
5.3 2)
Upon review of the training matrix, the inspectors noted that the radwaste Shipping Technicians, who are selected to attend the Radwaste Shipping Qualification class, have a retraining cycle of three years rather than a two year training cycle which would be required for individuals certifying the adequacy of radioactive waste shipments.
This was also characterized as a weakness.
QUALITY ASSURANCE PERSONNEL The inspectors reviewed training provided to guality Assurance personnel responsible for oversight of the radioactive waste/materials processing and transportation of radioactive materials.
The evaluation of the licensee's performance was based on a review of the Effluents Management training matrix, selected training records, and interviews with members of the Quality Assurance organization.
The Effluents Management training matrix requires selected members of the Quality Assurance organization to receive HP043,
"Radwaste Worker Training," on a two year retraining cycle and HP1001,
"Radwaste Shipping Qualification," training on a three year retraining cycle.
A review of training records indicated that these individuals had received the Radwaste Worker training, the Radwaste Shipping gualification course, and various other radwaste courses.
The individuals that were interviewed had received current Radwaste Worker
5.4 training.
However, none of these individuals had received the Radwaste Shipping gualification training within the last two years.
Although guality Assurance personnel are not primarily responsible for certifying the adequacy of radioactive material shipments, they do oversee various phases involved with the preparation of radioactive material shipments.
Although the technical quality of audits and surveillances reviewed by the inspectors were noted as very good, and no degraded performance has been identified, the lack of current Radwaste Shipping gualification training was noted as a weakness.
SHIPPING ENGINEERS The inspectors reviewed training provided to the individuals responsible for certifying the adequacy of radioactive material shipments within the Effluents Hanagement Organization.
The evaluation of the licensee's performance was based on a review of the Effluents Management training matrix, selected training records, and interviews with members of the Effluents Management and guality Assurance organizations.
The licensee has not developed an "in-house" training program, but rather relies on the assistance of third party (contractor) training to satisfy function specific training, such as training for the preparation and shipment of hazardous/radioactive waste, required by 49 CFR 172.700 Subpart HTraining.
The review indicated that two individuals assume responsibility for certifying the adequacy of radioactive material shipments.
One of the individuals had current training records for Radwaste Worker training and Radwaste Shipper gualification training.
This individual had also received recent training on the currently used computer code used to classify radioactive material shipments and to prepare shipping papers (RADHAN).
The other individual had current training records for Radwaste Worker training and had attended several seminars including an eight hour short course entitled
"Low Level Waste Training Short Course."
This training included a review of present and proposed low level waste transport regulations and packaging systems.
Based on this review, the inspectors could not determine if training had been received in accordance with 49 CFR 172.700 Subpart H Training.
Consequently, the inspectors asked to see the employer's certification that" the hazmat employee has been trained and tested, as required by that Subpart.
The inspectors were informed that training equivalent to the training requirements in 49 CFR 172.700 had been received, however, an employer certification that the individual had been trained and tested in accordance with the regulations was not performed and was not available.
In addition, no evidence was provided that the guality Assurance organization was performing the reviews of training and testing programs provided by third party (contractor) trainers, that would provide a basis for employer certification of 49 CFR 172.700 trainin The failure to provide an employer certification that individuals had been trained in accordance with 49 CFR 172 Subpart H-Training is considered an apparent violation of NRC requirements.
(VIO 50-387/94-24-
and 50-388/94-25-01).
6.0 IMPLEMENTATION OF THE SOLID RADWASTE PROGRAM 6.1 REGULATIONS AND LICENSES The inspectors performed a selected review to determine if the licensee had up-to-date copies of Department of Transportation (DOT) regulations, NRC regulations, and copies of licenses of the facilities to which shipments of radioactive material/waste were transported in 1994.
Up-to-date copies of DOT and NRC regulations pertaining to shipment of radioactive material were maintained in the Effluents Management conference room, and were verified present by the inspectors.
The inspectors also verified that the licensee maintained copies of licenses of all facilities to which the licensee had shipped radioactive material in 1994.
No deficiencies or violations of NRC requirements were identified.
6.2 PROCEDURES The inspectors performed a review of licensee procedures to determine if licensee management provided approved, detailed, instructions and
. operating procedures for personnel involved in transfer, packaging and transport of low level radioactive waste.
The evaluation of the licensee's performance in this area was based on a
review of the following management approved procedures.
NDAP-(A-0641, "Waste Management Program,"
Rev.
NDAP-(A-0648, "Shipping/Receiving of Radioactive Material," Rev,
NDAP-(A-0646, "Solid Radioactive Waste Process Control Program,"
Rev.
WM-PS-100,
"Shipment of Radioactive Waste,"
Rev.
WH-PS-110,
"General Shipment of Radioactive Material," Rev.
WM-PS-130,
"Shipment of Launderable Material," Rev.
WM-PS-150,
CFR 61,
"Non-Process Waste Stream Sampling,"
Rev,
WH-PS-155,
CFR 61,
"Sample Shipping and Correlation Factor Determination,"
Rev.
WH-PS-160,
"Rad Waste Curie Calculations,"
Rev.
WH-PS-170,
"Operation of HNS Bag Monitoring System,"
Rev.
WH-PS-185,
"Operation of the Second Sort Facility," Rev.
WH-PS-210,
"Packaging and Loading of DAW and Radioactive Material," Rev.
WH-PS-250,
"Use of RADMAN, TRASHP, RAMSHP and Filter Computer Programs" The inspectors found that procedures were up-to-date and revision numbers matched the procedures listed in the procedure index in areas
selected by the inspectors (Plant Library and Effluents Management Office).
The inspectors also noted that the detail and quality of instruction provided in the procedures were good.
The inspectors concluded that Waste Management procedures were being well maintained and controlled.
No discrepancies or deficiencies were identified.
7.0 WASTE TRACKING AND VOLUME REDUCTION EFFORTS The inspectors performed a review to determine if the licensee was tracking and trending the accumulation and rate of generation of solid and liquid radwaste, and to review efforts made towards minimizing the generation of radwaste.
The inspectors were informed that radwaste generation, accumulation, and disposal volumes and activities were routinely tracked and trended.
The inspectors were provided with a selected sampling of graphs used to track and trend radwaste.
The inspectors reviewed the following graphs.
Liquid Radwaste Recycled and Discharged Inputs to Liquid Radwaste Dry Active Waste, Generation, Accumulation, and Disposal Dry Active Waste versus Wet Waste Disposal Volumes Dry Active Waste Volume Solid Radwaste Disposal DAW Volume Disposed Processed Wet Waste Disposed
'otal Volume and Activity Disposed The inspectors noted that goals had been set for radioactive waste generation, accumulation, and disposal, and were routinely tracked and trended on clear legible graphs.
The inspectors noted that these graphs allowed for ease of tracking and trending and identification of abnormalities.
The inspectors were also notified that a "Wet Waste" team and a "Dry Active Waste" team had been assembled to evaluate waste volume generation and available methods and technologies to reduce radwaste volume.
Team members included representatives from Effluents Management, Nuclear Support, Chemistry, Health Physics, Operations, Maintenance, guality Assurance, and Construction.
Team meetings were scheduled approximately every two weeks and the teams are responsible for making recommendations and initiating implementation of approved initiatives.
The inspectors also noted various station postings and notices used to remind personnel of volume reduction methods and to solicit suggestions and support for radwaste volume reduction.
The inspectors noted that adequate progress was being made in this program area.
No deficiencies or violations of NRC requirements were identifie CHARACTERIZATION AND CLASSIFICATION OF WASTES 9.0 The inspectors performed a review to determine if requirements in 10 CFR 61.55(a)(8),
"Determination of Concentrations in Wastes,"
were being adequately addressed.
This area was evaluated by interviews with personnel and a review of procedures and relevant documentation.
The inspectors were informed that Teledyne Isotopes, Incorporated is contracted to perform sample analyses
.that are used to develop radionuclide scaling factors.
Samples representative of waste streams are collected and analyzed yearly for class B and C wastes, and every two years for class A waste.
Scaling factors had been developed for ultrasonic resin cleaner (URC),
cartridge filter, dry active waste, liquid radwaste filter media, liquid oil waste and sump sludge.
Scaling factors for activated corrosIon products were derived based on cobalt 60, scaling factors for fission products were derived based on cesium 137, and scaling factors for transuranics were derived based on plutonium 239.
Procedural requirements were in place to require scaling factors to be re-evaluated if significant changes occurred in plant operations that could change scaling factors greater than a factor of 10 (e.g.,
fuel leakage or changes in radwaste operations or equipment).
The inspectors noted good performance in this program area and no deficiencies or violations of NRC requirements were identified.
SHIPPING FOR DISPOSAL AND TRANSPORTATION OF OTHER MATERIALS Waste generators in the Commonwealth of Pennsylvania no longer had radwaste burial privileges at the time of the inspection.
Susquehanna Steam Electric Station (SSES)
now stores radioactive waste in an onsite facility referred to as the Low Level Radwaste Holding Facility (LLRWHF).
The licensee continues to make Low Specific Activity (LSA), Limited guantity (Lg), and Instrument and Articles (18A) radioactive material shipments while awaiting access to an approved burial facility.
The following radioactive waste/materials shipment records were selected and reviewe Shi ment Number 94-018 94-025 94-035 94-038 94-102 94-119
Ty e of Shi ment oxides on resin oxides on resin oxides on resin dewatered liquid radwaste filter media dewatered RWCU filter media Laundry Activity (mCi)
6.8 E2 3.1 E5 3.6 E4 2.8 E4 3.3 ES 8.63 These records were found complete.
The licensee maintained copies of the consignee's licenses as required.
No discrepancies and no violations of NRC requirements were identified.
10.0 LOW LEVEL RAD WASTE HOLDING FACILITY The inspectors performed reviews of the Low Level Radwaste Holding Facility including safety reviews, start-up and operations, and controls for liquid effluents.
Licensee performance in these areas was evaluated by a review of procedures, safety reviews and supporting calculations, tours of the facility, and discussions with cognizant personnel.
10.1 LLRWHF SAFETY REVIEWS The inspector s reviewed Safety Evaluation NL-92-007, "Operation of the LLRWHF at SSES,"
and the following selected calculations used to support the Safety Evaluation.
Bases for Calculations:
LLRWHF Source Terms, PLI-70876, March 30, 1992 Bases for Calculations:
LLRWHF Source Exposure Rate Profiles, PLI-71060, April 20, 1992 Calculation No. OT-92-RKB-014,
"Annual Dose and Exposure Rates to Walls for Operations at LLRWHF" Calculation No. OT-92-RKB-007, "Accident Dose Analysis for LLRWHF Dry Active Waste (DAW) Fire" Calculation OT-92-RKB-013,
"LLRWHF Calculation of Direct and Skyshine Dose Rates" The inspectors noted that the methods, assumptions, and calculations of source terms and resultant dose rates and doses were thorough, comprehensive, and of high quality.
These calculations were characterized as excellent by the inspectors.
The inspectors also noted some of the supporting calculations for the safety review identified the need for additional administrative or engineering controls for the LLRWHF (e.g.,
storage requirements for reactor water clean-up (RWCU) and Cartridge Filter Liner Storage Modules (LSMs) to ensure compliance with
site boundary dose rates).
The inspectors were informed that administrative controls were in place to address these concerns and included use of supervisory controls over storage of materials at the LLRWHF, periodic radiation surveys, and use of thermoluminescent dosimetry monitoring devices.
The inspectors pointed out for licensee consideration that, although no compliance or performance problems were identified, consideration could be given to actually including in procedures the specific storage requirement recommendations that were identified in supporting calculations for the safety review.
The licensee's evaluation of this area will be reviewed in a future inspection.
No deficiencies or violations of NRC requirements were identified.
START-UP AND OPERATIONS The inspectors reviewed the following documentation to determine if adequate guidance was available for the operation and use of the LLRWHF.
NDAP-00-0643,
"Use of the Low Level Radwaste Holding Facility" WM-PS-402,
"LLRWHF Container Inspection" LLRWHF Status Inventory of Radioactive Wastes LLRWHF Status Inventory of Radioactive Materials Safety Evaluation No. NL-92-007, "Operation of the LLRWHF at SSES" The above documentation provided information on responsibilities for management of the facility, requirements for radioactive wastes and radioactive material storage, shipments from the LLRWHF, ALARA controls, contamination controls, container integrity surveillance, and inventory.
The documents were found to provide satisfactory guidance for the operation and use of the facility.
The inspectors also performed a tour of the LLRWHF to assess storage capacity, methods for storing radioactive materials and radwaste, administrative controls, and compliance with established procedures.
The inspectors observed ample capacity to store radioactive wastes and radioactive materials.
The LLRWHF was originally designed to safely store approximately 240,000 cubic feet of low-level radioactive waste.
The construction and maintenance of this facility represents a
significant licensee effort towards onsite safe storage of radioactive wastes and materials.
Storage areas for radioactive wastes and materials were well posted, and stored materials and wastes were arranged in a neat and orderly manner.
The inspector also noted the presence of the following.
reinforced concrete vaults shielded storage modules remote controlled crane floor drain system non-radiological ventilation system emergency lighting radiation monitoring system
fire detection/protection system, and access controls The inspectors noted that the LLRWHF was adequately maintained.
In addition, the inspector noted compliance with Nuclear Department Procedure NDAP-00-0643,
"Use of the Low Level Radwaste Holding Facility," including management controls, performance of visual inspections, performance of radiological surveys, and performance of radioactive wastes and radioactive material inventories.
The general operation of the LLRWHF was very good.
No deficiencies or violations of NRC requirements were identified.
EFFLUENTS Under normal conditions there are no free liquids inside the LLRWHF.'ree liquids entering the facility originate from fire protection water, rainwater or snowmelt from roof leakage, cooling system or fuel leakage from miscellaneous equipment inside the facility, and liquids brought into the facility on vehicles.
A curb system has been set up to contain any liquids and a floor drain system was installed to route liquids to a set of floor drain sumps.
Each sump is equipped with liquid detection devices that provided a signal to the main plant and LLRWHF control rooms if liquids reach a preset limit.
There are no piping connections between the LLRWHF and the main plant.
Generated liquids are pumped to a container, sampled for radioactivity, and disposed of in accordance with plant procedures..
The inspectors reviewed results of a gamma spectroscopy analysis of a LLRWHF sump sample obtained on September 27, 1994.
The inspectors noted that the counting systems minimum detectable concentration was below the lower limit of detection required for liquid effluents as required by Chemistry Procedure CH-AD-001, and results met criteria for release of liquid effluents.
The inspectors concluded that controls for liquid effluents at the LLRWHF were good.
No deficiencies or violations of NRC requirements were identified.
EXIT INTERVIEW The inspectors met with the licensee representatives denoted in Section 1.0 at the conclusion of the inspection on November 4, 1994.
The inspectors summarized the purpose, scope and findings of the inspection.
The licensee acknowledged the inspection findings.