IR 05000395/1987027
| ML20235K724 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/16/1987 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235K696 | List: |
| References | |
| TASK-2.F.1, TASK-TM 50-395-87-27, IEIN-87-031, IEIN-87-31, NUDOCS 8710050210 | |
| Download: ML20235K724 (6) | |
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Ua3lTED STATES I
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MUCLEAR REGULATORY COMMISSION
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Licensee:
South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.:
50-395 License No.:
NPF-12 Facility Name:
V. C Summer Inspection Conducted:
September 8-11, 1987
/4/87 Inspector:
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F. N. Wrfght Date Sigrfed '
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pC.M.Rosey,SeqionChief Date Signed Division of Radiation Safety and Safeguards j
i SUMMARY Scope:
This routine, unannounced inspection of the radiation protection program included:
previous enforcement matters; organization and management controls; external exposure control; solid waste processing; transportation of radioactive material; and facilities and equipment.
Results:
No violations or deviations were identified.
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'i REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. R-Baehr, Manager, Corporate Health Physics and Environmental Programs-
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L. A. Blake, Specialist, Hea'lth Physics
- D.' C. Blanks, Engineer, Licensing
- M. N. Browne, Group Manager, Technical _'and Support Services
- J. Cox, Associate Manager, Health Physics T. Frady, Associate Manager,. Quality. Assurance Surveillance
- A. J. Ginyard, Supervisor, Quality Control G. J. Guy, Coordinator,' Radioactive Waste G. G. Hall, Associate Manager, Radiological Analytical Services P. S. Hughes, Supervisor, Health Physics
- D. Moore, Director, Quality and Procurement Services
- J. M. Paglia, Manager, Licensing
- G. Parsons, Engineer, Independent Safety Evaluation Group
- R. Sweet, Specialist, Quality Assurance Surveillance
- M. B. Williams, Group Manager, Nuclear Regulatory Development Services
- W. A. Williams, Jr., Special Assistant, Nuclear Operations, South Carolina Public Service Authority J. Wilson, Specialist, Health Physics Nuclear Regulatory Commission P. Hopkins, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September 11, 1987, with those persons indicated in Paragraph 1 above.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92702)
(Closed) Violation 50-395/87-10-01:
Failure to properly classify a radioactive waste shipment in accordance with the requirements of 10 CFR 61.55 and 61,56.
The inspector reviewed and verified the corrective actions as stated in South Carolina Electric and Gas Company (SCE&G) letter dated June 4, 1987.
4.
Organization and Management Controls (83722)
The licensee is required by Technical Specification 6.2 to implement the plant organization as shown in Figure 6.2-2.
The responsibilities,
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authorities, and other management controls were further outlined in Chapters 12 and 13 of the Final Safety. Analysis Report (FSAR).
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The inspector reviewed the licensee's organization staffing level and lines of au.thority 'as they related to radiation protection, radioactive material control and transportation of radioactive ' material and verified that the licensee had not made ' organizational changes which would'
adversely affect the ability of the licensee to control radiation exposures and radiological material i
In the past,.the licensee has utilized a vendor to demineralize liquid radioactive waste and dewater solid radioactive waste.
The licensee recently purchased a new demineralization (demin) system and plans to operate it with licensee personnel.
The licensee also has plans to have radioactive waste personnel performing dewatering activities by October 1987.. The inspector determined that a new Radioactive Waste Coordinator position had been added to the Health Physics group and filled in July 1987.
The Radioactive Waste Coordinator will have the responsibility to plan and coordinate the cally radioactive waste activities.
Through discussions with licensee representatives, the inspector determined that the new Radioactive Waste Coordinator is the first engineer assigned to the health physics group and previously served as a Shift Technical Supervisor at the facility.
No violations or deviations were identified.
5.
External Occupational Exposure Control and Personnel Dosimetry (83724)
10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such equipment.
During tours of the plant, the inspector observed workers wearing appropriate. personnel monitoring devices.
10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material.
Additional requirements for the control of high radiation areas are contained in Technical Specification 6.12.
During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contaminated areas, radioactive material areas and the labeling of radioactive material.
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The inspector reviewed the quality controls for the licensee's thermoluminescent dosimetry (TLD) analysis equipment.
The inspector determined that the specialist allowed to operate the TLD reader must demonstrate an understanding of the various quality control and operating procedures and receive 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of annual retraining on the system. The inspector determined that one person on the staff had attended a 3-week training program which included basic TLD theory and specific instructions on the licensee's TLDs and TLD readers.
The ' inspector reviewed the
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.following quality control procedures for the licensee's TLD reader.
ESP-1210, Panasonic UD-710-A Automatic Reader Quality Control, Revision 4, dated September 15, 1986
ESP-1213, Panasonic Dosimeter Quality Control, Revision 2, dated October 1, 1986 l
ESP-1216, Panasonic Dosimetry Recordkeeping and Data Management,
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Revision 2, dated October 1, 1986 l
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The inspector reviewed the TLD reader log book and selected various quality control records for reviews. The inspector also reviewed selected calibration records for the readers.
The inspector verified that the measured parameters were within acceptance criteria as specified in the
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quality control procedures.
No violations or deviations were identified.
6.
Facilities and Equipment (83727)
By observation and discussion with licensee representatives, the inspector determined that there had been no changes to the licensee's facilities and equipment for radiation protection activities which adversely affected the radiation protection program.
The licensee has moved its dosimetry issuance and whole body counting operation into a new security access building which significantly increased the working space available for peak usage.
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No violations or. deviations were identified.
7.
Solid Waste (84722)
10 CFR 20.311 requires a licensee who transfers radioactive waste to a land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56.
10 CFR 61.55(a)(2)-(a)(7) describes the manner in which the classification is to be computed, based on concentrations of certain radionuclides within the waste.
I 10 CFR 61.55(a)(8) permits the use of indirect methods, such as scaling l
f factors, to determine concentrations of difficult-to-measure radionuclides provided there is reasonable assurance that the indirect methods can be correlated with actual measurements.
The licensee had established scaling factors for several difficult-to-measure radionuclides based on direct measurements of cesium-137 (Cs-137), cerium-144 (Ce-144), and Cobalt-60 (Co-60).
While
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reviewing' the shipping papers of several radioactive waste shipments, the
' nspector determined that the licensee had not always-detected Ce-144, i
Cs-137, and Co-60 in secondary.- demin resin radioactive waste -samples.
Through interviews with licensee representatives the inspector determined that -when the. radioactive waste shipments in question were made, an activity for each undetected key radioisotope had been calculated.
The licensee calculated values of the key isotopes utilizing the. isotopes percent abundance from the previous composite sample (used to establish
waste grab sample. The total activity of the ' grab sample was multiplied
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the scaling factors) and the total activity measured in the radioactive i
by the specific isotopes percent of abundance from the composite sample to derive a key isotope activity. The derived activity for the key isotopes Ce-144, Co-160 and Cs-137 was then' utilized with developed scaling factors, waste volume, and waste density to determine the activity of difficult-to-measure radionuclides.
The inspector determined that the licensee no longer' calculated a concentration for key radionuclides based on previously identified abundances when they were not measured in grab sanples.
Instead the licensee. was utilizing the isotope's lower level of detection (LLD) when key isotopes were not measured.
The inspector stated that while the licensee's methods appear to 'bc conservative, a direct measurement of the key radioisotopes utilized for scaling di f ficul t-to-mea sure radionuclides was preferable to either calculating a key isotope activity or using a LLD value.
Licensee representat1ves agreed to review the existing procedures for classifying low level radioactive waste and examine procedural alternatives that could be utilized to improve the accuracy of the licenee's waste classification program and assure that the indirect methods utilized to infer difficult-to-measure radionuclides can be correlated with actual measurements.
The inspector stated that the result of the licensee evaluation and any subsequent modifications to its waste classification program would be reviewed in future inspections as an inspector followup item (50-395/87-27-01).
10 CFR 61.56(b)(1) requires waste to have structural stability which will generally maintain its physical dimensions and form under expected disposal conditions.
Through discussions with licensee representatives and review of selected records, the inspector determined that waste stability, when required, was achieved by use of approved containers or by solidification.
i No violations or deviations were identified.
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Transportation of Radioactive Material (86721)
10 CFR 71.5 requires that each licensee who transports licensed material outside the confines of its plant or other place or use, or who delivers licensed material to a carrier for transport, shall comply with the
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applicable requirements of the regulation appropriate to the mode of
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transport of the Department of Transportation in 49 CFR Parts 170 through 189.
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l The inspector reviewed selected records of radioactive waste = shipments and non-exempt.. radioactive materials shipments performed during 1987, and verified that the. requirements of 49 CFR Parts'170 through 189 had been met for those shipments. The inspector observed the labeling of packages, placards, quality ' control checks, and made independent surveys for two radioactive material shipments leaving the facility during the inspection.
No violations or deviations were identified.
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Inspector Followup Items (92701)
(Closed)' Inspector. Followup Item 50-395/87-10-02 NUREG-0737 Item II.F.1;(3) requires type test of representative specimens
.of containment high range monitors to demonstrate linearity through.all scales up to 105-Roentgen per hour.
The type test data showing linear response to radiation through all ranges up to 8x10' R/hr was reviewed for containment high range monitors model Victoreen 877-1.
10.
IE Information Notices (IEN) (92717)
The inspector. determined that Information Notice No. 87-31, Blocking, Bracing, and Securing of Radioactive Material Packages in Transportation, had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.
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South' Carolina Electric and Gas Company ATTN: Mr. D. A. Nauman, Vice President Nuclear Operations P. O. Box 764 (167)
Columbia, SC.~29218 Gentlemen:.
i SUBJECT: NRC INSPECTION REPORT N0. 50-395/87-27 l
'In ' the cover letter. for the subject Inspection Report, the dates of the inspection were erroneously stated as August 8-11, 1987.
The letter should have indicated that the inspection took place September 8-11, 1987.
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We regret any inconvenience this error may have caused you.
Sincerely, Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards cc:
0. S. Bradham, Director,
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Nuclear Plant Operations J. L. Skolds, Deputy Director
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Operations and Maintenance J. B. Knotts, Jr.
Debevoise and Liberman W. A. Williams, Jr., Special Assistant, Nuclear Operations -
Santee Cooper-A. M. Paglia, Jr., Manager Nuclear Licensing bec: NRC Resident Inspector J. Hopkins, Project Manager, NRR Document Control Desk State of South Carolina Ril'
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.tilv CNih NM FWright CHos6 HDance 9/23/87 9g/87 9/g/87 C/O I.
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