IR 05000416/1987023
| ML20236C852 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/16/1987 |
| From: | Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236C824 | List: |
| References | |
| 50-416-87-23, IEIN-87-003, IEIN-87-007, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8710270368 | |
| Download: ML20236C852 (15) | |
Text
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mReport No.: <5.0-416/87-23- ' < ' - , . , Licensee::! System Energy-Resources, Inc.
~ ?j . , , ' Jackson', MS, 39205 ~ '
' - s-7.j!? Docket No.: o50-416., ' License No.: NPF-29 j ,. " + ... .,, . Grand Gulf Nuci pg Station j + Facility Name: . . s.
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7' In'spection,Cdnducte': - September 28-October.2,.1987 , ' ' I
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- Inspector:
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X c F. N. Wright G' Date Signed: - JApproved by: % /6 /n, /J7 < , C. M..Hosey,'Sectiqn Chief . Date Signed J Division of Radiatibn Safety and' Safeguards , SUMMARY
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~ Scope: - This. routine, unannounced inspection of the - radiation protection - program included:._ organization and_ management controls of<the health physics ~ . staff; control of' radioactive materials Dandi contamination, surveys and -. . monitoring;. external exposure, controland personnel! dosimetry; internal ~ ..i exposure - control; training. and : qualifications; solid radioactive waste, transportation"of radioactive material; radiation controls. for'drywell during.
fuel: movement; and" the licensee!s ~ program for maintaining radiation doses as.
+ .. low as reasonably achiev'able (ALARA) - . . Results:' LNo~ violations or deviations were identified.
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? ! i REPORT DETAILS . ; 1.
Persons Contacted Licensee Employees i L. Adler, Supervisor, Health Physics
- J. D. Bailey, Compliance Coordinator
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- K. Beatty, Administration Assistant D. M. Boone, Supervisor, Health Physics-l J. Cotton, Supervisor, Health Physics l
S. R. Cotton, Specialist, Health Physics J. Ewell, Specialist, Health Physics
- R. C. Fron, Manager, Emergency Preparedness J. R. Gerber, Senior Quality Assurance Representative
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- R. T.Halbach, Administration Assistant
- P. L. Hayes, Supervisor, Training Support
- T. O. Hildebrandt, Supervisor, Radiation Control - Technical
- J. Hurley, Coordinator, Emergency Preparedness J. L. Hurst, Supervisor, Health Physics C. R. Hutchinson, General Manager J. E. Landers, Supervisor, Health Physics
- J. V. Parrish, Superintendent, Chemistry and Radiation Control
- J. C. Vincelli, Technical Assistant, Chemistry and Radiation Control
- T. M. Wilkerson, Supervisor, Radiation Control - Operations J. D. Williams, Supervisor, Health Physics
- M. J. Wright, Manager, Plant Support Other licensee employees contacted included four maintenance craftsmen, six technicians, and four trainers.
Nuclear Regulatory Commission
- R. Butcher, Senior Resident Inspector J. Mathis, Resident Inspector
- Attended exit interview
.i 2.
Exit Interview The inspection scope and findings were summarized on October 2,1987, with those persons indicated in Paragraph 1 above.
The following items were discussed in detail: one apparent licensee identified violation for , failure to adhere to radiation control procedures (Paragraph' 6) and an inspector followup item concerning the licensee's programmatic controls to ensure personnel radiation exposures in the drywell during fuel movement were adequately controlled and maintained as low as reasonably achievable (ALARA)(Paragraph 12).
The licensee acknowledged the inspection findings and took no exceptions.
The licensee did not identify as proprietary any
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2 of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (92702) This area was not inspected during the inspection.
4.
OrganizationandManagementControls(83722) The licensee is required by Technical Specification (TS) 6.2 to implement .the plant organization as shown in Figure 6.2.2-1.
The responsibility, authorities, and other management controls were further outlined in Chapters 12 and 13 of the Final Safety Analysis Report (FSAR).
The inspector reviewed the licensee's organization and management controls for the radiation protection, transportation, and radioactive waste
programs including changes in the organizational structure and staffing.
The inspector determined that the licensee had made several organizational changes within the health physics group. The radiation control supervisor (RCS) of operations changed positions and is currently the radiation control supervisor of' the technical section and a new radiation control supervisor of operations was selected.
The former RCS of the technical section became the permanent Technical Assistant to the Chemistry Radiation Control Superintendent.
The Technical Assistant position had previously been a temporary position and has been made a permanent staff position.
In addition, three former Health Physics Specialists became Health Physics Supervisors in newly created positions.
The new positions included a Health Physics Supervisor of dosimetry processing, dosimetry records and administration, and instrumentation.
The licensee has also added a sixth operating shift for health physics.
i The new shift was added to allow one week in the rotation for training ' purposes, allow each health physics crew to work with the same operation crew on backshift, and improve working conditions (the additional shift will allow rotating crews more weekends off).
The licensee also transferred the health physics training specialist from the technical section to the operational section to improve operations related training
' capabilities.
, Since the March inspection, the licensee has lost one health physics , I
supervisor and three technicians.
The current approved staffing level is , at 70 with 66 positions filled.
The licensee is currently working about l 3% overtime. During the outage the licensee plans to work six twelve hour l shifts.
j At the time of the inspection, the licensee had no contract health physics support onsite.
The licensee does not rely on contract personnel to
support routine operations or supplement technical capabilities.
The licensee was in the process or reviewing contract personnel qualifications and making selections of personnel for the fall refueling outage.
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- licensee lutilized Procedure 08-S-01-15, Section and Qualification, of Contract. Health Physics ~ Personnel, lto establish guidelines and criteria for ' the selection of contract health physics personnel. _ Through-interviews with licensee representatives,. the inspector determined that the licensee plans to bring 84 contract personnel onsite to' support the
'second. refueling outage.
The number is ten more than was requested for, the first refueling outage.
.The established contract support. includes support for-outage job coverage, dosimetry, radwaste, ALARA, and-instrumentation.. The licensee requires all contract-support personnel to ' functionally report to-licensee employees.- No viola' ions or deviations were identified.
t 5.
Training and Qualifications-(83723)' The.. inspector reviewed-the training aspects of the licensee's -radiation . protection program including: the status of.the Health Physics training program-accreditation, continued. health physics training,.and general employee-training.(GET).
The licensee received Institute of. Nuclear Power Operations (INP0) accreditation of its Health Physics and Chemistry Training ' programs in June-1987. -Completion of the accreditation process had originally been . scheduled for 1988.
Technical. Specification 6.4 states that a retraining and replacement training program for the facility staff shall meet.or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
Paragraph 5.5 of ANSI N18.1 states that a training program shall be established which maintains the proficiency of the operating organization through periodic training exercises, instruction periods and reviews.
The licensee has added a sixth HP operations shift to allow for ongoing training every sixth week. The continuing training addresses basic health physics subjects as well as current issues.
The training is coordinated by the licensee's training group.
10 ~CFR 19.12_ requires the licensee to instruct all in'dividuals working in.
or frequenting any portion of the restricted area in the health protection problems associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposures, and in the purpose and functions of protective devices employed, applicable provision of Commission regulations, individual responsibilities and the availability .of radiation exposure data.
As part of the GET training for Radiation Level II workers, licensee employees are required to participate in a practical exercise.
The inspector attended one of the practical exercises.
In the exercise, . licensee employees entered a classroom in groups of four or less and were given an access control card (dosimetry record) for a fictional person along with a thermoluminescent dosimeter (TLD) and a self-reading pocket _ _ - - _ - -
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Each employee was also given a radiation work permit (RWP) package which included a pre job briefing, ALARA pre-job planning checklist, survey map, ALARA job exposure estimate form, and a list of additional protection requirements for RWP entries.
The students were _' allowed to review the information and RWP requirements.
After the review, instructors with evaluation' check sheets questioned the employees on their knowledge.of the specific requirements to enter the mock up radiation and contaminated area.
Students were then required to don the required protective clothing specified in the RWP, complete the dose card, and enter the mock up area. The mock up area was another classroom posted and zoned.as a radiation and contaminated area.
Students entering the mock up area were individually met by another GET instructor where they were questioned on the radiological conditions of the area, asked to calculate exposures, and evaluated as to their response to potential problems. The students were then monitored while removing their protective clothing and during frisking techniques.
The employee's training was completed upon completion of the exercise. The exercise was comprehensive and emphasized one-on-one evaluations of student performance.
In general, the observed students were attentive and knowledgeable of questions asked by instructors.
Whenever a wrong answer was given or an improper action made, the instructors provided guidance and corrected the student's error.
The inspector discussed the training program with students who had completed the training and detennined that the students interviewed were aware of ALARA concepts and personnel exposure limits.
No violations or deviations were identified.
6.
External Exposure Control and Personnel Dosimetry (83724) The inspector reviewed the licensee's external exposure control and '; personnel dosimetry programs, including: licensee identified problems associated with its TLD monitoring program; use and calibration of pocket chamber dosimeters; TLD and PD discrepancies; and posting, labeling, and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive material.
a.
TLD Program The licensee received National Voluntary Laboratory Assessment Program (NVLAP) accreditation for its dosimetry measurement program in 1986, and parallel tested its program with a vendor's until its implementation in January 1987.
During July 1987, licensee representatives notified NRC staff in Region II of plans to replace the licensee's TLD measurement program . with a vendor's due to problems encountered with the licensee's TLD ' monitoring equipment.
l In January 1987, numerous measurements of low level neutron exposures were found on the licensee's December 1986 TLDs.
The licensee
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suspected a problem with its dosimetry since the reactor had not been ! at power during December 1986.
In the licensee's TLD monitoring program the licensee utilizes three categories of TLD's; reference, control, and field.
The reference ) TLDs are only used to generate and verify Element Correction Factors l (ECFs) for field TLDs.
The ECFs are factors used to standardize the
variable light output so that a constant response is obtained when similar TLD elements of different TLDs are exposed to the same amount of radiation.
In the licensee's TLD, lithium borate phosphors (LioB 0 ), elements
I and 2, are sensitive to neutrons where the caltium sulfate phosphors (CaSO ), elements 3 and 4, are insensitive to neutrons. An
increase. in the ratio of lithium borate response to calcium sulfate response is an indicator in the licensee's alogrithm of neutron , exposure.
The licensee's investigation showed that a bias for the lithium borate elements had been introduced in the monitoring program from underresponding control TLDs used in calibrating the equipment.
The under responding control TLDs caused an apparent increase 'n elements 1 and 2 of the field TLD response indicating the presence of neutrons.
The underresponse was caused by fogging of the TLD phosphors' protective cover or bubble. The licensee found fogging on the teflon bubbles covering the lithium borate phosphors on 140 of its 200 reference TLDs,150 of its 200 control TLDs, and 400 of its 2,000 field TLDs.
Test showed the fogging material to be lithium borate which had mixed with moisture in the bubble and apparently hoiled off during the annealing / reading processes.
The licensee sivaged the remaining TLDs and was able to recalibrates its equipment . prior to reading the January 1987 TLDs.
The licensee continued to
research the moisture fegging problem and ordered new TLDs.
In July 1987, the licensee's dosimetry staff was faced with the task of determining ECFs for 7,500 TLDs and providing outage support for a refueling outage in November 1987. The licensee decided to revert to
the vendor TLD program utilized prior to 1987 until the dosimetry l program was more secure.
, -In August 1987, the licensee identified another problem with its i dosimetry program.
In setting up the licensee's dosimetry program, the licensee selected 200 TLDs as reference TLDs used to generate ECFs for field TLDs.
The reference TLDs are exposed to a known amount of radiation and read.
The mean of each element is then determined and the coefficient of variance (CV) calculated to evaluate the variation of the measurements.
The CV expresses the variation as a fraction of the mean and could be used to determine problems in TLD construction or deterioration or poor TLD alignment during processing.
Low CVs are desirable and indicate the spread of data is narrow.
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Licensee Procedure 08-S-07-35, Operation of the Panesonic UD-710A Automatic TLD Reader, Revision 2, dated. April 25, 1986, required the coefficient of variance. to be equal to or less than 5 percent for reference element means-when ECFs for TLDs were being generated.
During the NVLAP testing period all calculations were performed manually.
Between the period of NVLAP testing and the onsite NVLAP review, organizational changes occurred on the licensee's dosimetry staff.
The specialist overseeing the setup of the dosimetry program accepted a new position and was replaced and the technician working with the specialist left the company.
Later the licensee received NVLAP accreditation for the period of May 1, 1986, to July 1,.1988.
Through interviews with licensee representatives the inspector determined that the calculations to ensure reference element means had a coefficient of variance less than 5 percent were not performed from around July 1986 to July 1987.
One of the conditions that contributed to the problem was that the procedure for selecting and screening TLDs, 08-S-02-39, Selection and Screening of Thermoluminescent Dosimeters, Revision 1, dated January 15, 1986, did not specify the requirement to calculate the CV for reference TLD element means.
Instead the requirement was specified in the operating procedure for the automatic TLD reader, 08-S-07-35.
The.
licensee issued a temporary change to 08-S-02-39, Selection and Screening of Thermoluminescent Dosimeters, dated August 24, 1987, requiring CV calculations in the evaluation of TLDs.
The licensee identified the problem on a Quality Deficiency Report 482-87 dated September 17, 1987.
Technical Specification 6.8.1.a requires written procedures to be established, implemented, and maintained to cover activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,1978, requires written procedures for personnel monitoring.
Radiation Protection Instruction 08-S-07-35, Operation of the Panasonic UD-810A Automatic TLD Reader, dated Apr11L 28, 1986, requires the licensee to verify that the CV for refecence element means is equal to or less than 5 percent when generating ECFs for TLDs.
Failure of the licensee to insure that the CV for element means was less than or equal to 5 percent when determining TLD ECFs was identified as an apparent violation of TS 6.8.1.a; however, pursuant to 10 CFR 2, Appendix C.V. A it was determined that a Notice of Violation would not be issued due to licensee self identification of the problem.
The licensee begins the NYLAP decertification process in the fourth quarter of 1987, and expects the onsite visit to occur in the first quarter of 1988.
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i The licensee plans to have its dosimetry monitoring program ! operational by January 1,1988.
i b.
Self Reading Dosimeters l The inspector reviewed the following licensee procedures: . 08-S-01-70, Health Physics Instrumentation, Revision 8, dated-June 11, 1987 08-S-07-17, Operation and Calibration of. Shepherd Model 142-10 Panoramic irradiator, Revision 3, dated. June 19, 1986 l 08-S-07-26, Operation and Calibration of Direct. Reading X and Gamma , Radiation Dosimeters, Revision 4, dated September 14, 1986 08-S-07-37, Pocket Dosimeter /TLD Comparison, Revision 4, dated April 3,1987 A computer tracking (SRDs).
system tracks the calibration schedule for self > reading dosimeters Each month the computer generates a list of SRDs requiring drift testing and response check. A portion of the SRDs (200-500) are removed from service each month by the dosimetry group and forward to the instrumentation group for testing.
The SRDs are zerced and placed in a low background area for a 48 hour drift i test.
SRDs having a drift exceeding 5 percent of full scale are retested if the SRD fails the subsequent test the dosimeter is , removed from service.
Approximately two to five percent of the licensee's SRDs were failing the drift test each month.
The dosimeters are response checked to a value at 75 percent of full scale and must be within 10 percent of the exposed value to pass.
q If the SRD fails the subsequent response check the dosimeter is j removed from service.
The inspector reviewed selected records of dosimeters that had passed the drift and response check.
The licensee's records do not show measured results of the test.
The records according to procedure are l only required to show passed or failed condition.
The licensee was- ! in the process of evaluating the performance of two vendor's SRDs.
q Licensee representatives reported that one of the vendors had a- ' response check failure rate of 20-30 percent, the majority of which overesponded.
The inspector reviewed the calibration data for the licensee's source utilized to response check SRDs and TLDs.
Licensee procedures I require the source to be calibrated every six months utilizing ) condenser R meters traceable to the National Bureau of Standards.
The inspector reviewed the most recent calibration results and verified that the source was within 10 percent of the expected values.
The licensee has the calibration ring source with remote l control capabilities installed in an unused room in the offgas j l l l <
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The inspector had to tour the room with a portable flood light as the overhead lamps were not working.
The inspector ! identified the lack of lighting as a safety hazard to licensee j I management.
I No violations or deviations were identified, c.
TLD/SRD Discrepancy Investigation ! The inspector reviewed selected evaluations of TLD and SRD
comparisons. The licensee evaluates TLD/SRD differences greater than-25 percent and +35 percent when the TLD value exceeds 500 millirem and greater than 140 percent when the TLD value is less than 500 millirem.
In each investigation report examined, the licensee found the reason for the discrepancy, however, in at least one example, the error was found without determining the root cause of the problem. Licensee management agreed to look for and document the root cause of the discrepancy in investigations reports.
No violations or deviations were identified.
d.
Posting, Labeling and Controls The inspector toured the licensee's containment building, auxiliary building, radwaste, offgas, turbine, and shop areas.
The inspector obtained a copy of the licensee's radiation areas where the whole body exposure was greater than 1 Rem per hour and selected various rooms for a locked door check.
The licensee was experimenting with various sized automatic door closures to assist in maintaining high radiation areas locked.
The inspector verified that all high radiation doors examined were properly secured.
The inspector reviewed the posting of areas and labeling of radioactive material. The inspector compared the postings and survey information for selected rooms and verified that they were properly posted per documented conditions.
No violations or deviations were identified.
7.
Internal Exposure Control (83725) The inspector reviewed the respiratory training program, the use of plant breathing air, and observed the use of respiratory protection equipment.
The inspector attended selected portions of the licensee's respiratory training program including classroom instruction, practice exercises, and respiratory fit testing, j The licensee does not have a dedicated breathing air distribution system throughout the facility. The licansee utilizes breathing air purifiers in conjunction with the service air system for air line respirators and i
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' operates a breathing air compressor for filling self contained breathing apparatus (SCBA) bottles.
The air purifiers utilize a catalyst to ~ climinate-carbon monoxide, coalescing type oil removal filter to remove oil mist, activated carbon absorption filters to remove hydrocarbon odors.
Each ' purifier has two filter columns which may be automatically cycled.
Each filter column-has a humidity indicator _ which changes from green to yellow when the humidity is. too high.
The high humidity indicator ' . indicates expiration f of. the catalyst which converts carbon monoxide to n _ carbon dioxide.
Licensee procedures required that the purifier be exemined by health physics for operability each hour that the unit.is in service.
No units were in service for radiological protection activities during the inspection.
The inspector reviewed the licensee's testing and evaluation of breathing ) air quality from the._ service. air systems with the purifiers and the l compressor utilize to fill SCBA bottles.
The test results showed the air ! to meet the certification requirements of grade D air.
The inspector observed the use' of full face respirators in various jobs' in the licensee's radwaste and auxiliary buildings.
No violations or deviations were identified.
8.
Maintaining Occupational Exposures As low As Reasonably Achievable (ALARA) -(83728) 10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable.
The recommended elements of an ALARA program are contained in Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Station will be ALARA and Regulatory Guide 8.10, Operating a Philosophy for Maintaining Occupational Radiation Exposures ALARA.
The inspector reviewed the status of the licensee's ALARA program activities and goals for 1987.
The licensee was in the process of compiling man hour estimates for various work task scheduled for the refueling outage number two to began . in November,1987.
The license had originally planned to operate the reactor at reduced power during the summer and delay refueling until 1988 I The ALARA group established two ALARA man-rem goals for 1987, one for 200 man-rem without the refueling outage and another of 425 man-rem to include planned outage work.
As of September 1, 1987, the licensee had accumulated 85.7 man-rem or approximately 43 percent of its 1987 non outage goal. The licensee's 1988 ALARA goal has been set at 195 man-rem.
The licensee was in the process of installing permanent lead shielding l around 10 inch suppression pool cooling and cleanup piping. The inspector observed the shielding work on the 119 foot elevation of the auxiliary
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the lower containment access.
The shielding was installed to reduce the radiation levels near dress out and control point areas.
Lead sheets were pressed and bound around the suspended piping.
The inspector reviewed the design change package for the shielding project.
The design change package included a safety evaluation form and an unreviewed safety questionnaire.
The licensee has added two employees to the ALARA staff to support the expanding ALARA involvement.
The staff now contains an ALARA Specialist and three health physicists.
Ongoing ALARA activities include: the development of a shielding tracking system for portable lead shielding; installation of a camera and monitor in the: reactor waste cle6nup pump room, and; the evaluation of cameras.
designed for harsh environments, communication equipment and expanding
scaffolding, d l No v'iolations or deviations were identified.
9.
Surveys, Monitoring and Control of Radioactive Material (83726) 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys a (1) may be necessary for the licensee to comply with the , regulations and (2) are reasonable under the circumstances to evaluate the j extent of radiation hazards that may be present, j The inspector reviewed the licensee's program for control of radioactive I materials and contamination, including: the use of the hot tool room, l surveys of material exiting the radiation control area (RCA), surveys of protective clothing and surveys of the facility operating areas.
, i' The inspector reviewed the following licensee procedures: 01-S-08-2, Exposure and Contamination Control, Revision 11, dated September 4,1986 and 08-S-01-73, Tool Use in Contaminated Areas, Revision 1, dated
January 21, 1987 j l Licensee Procedure 08-S-01-73 provides guidelines and controls for use of ) tools and equipment in contaminated areas.
The licensee has a hot tool l room where tools with fixed contamination or tools with potential internal j contamination are stored for use in contaminated areas.
The Tool and Equipment Supervisor is responsible for the hot tool room. Access to the hot tool room is made through the tool and Equipment Supervisor.
The inspector and a licensee representative toured the hot tool room.
The inspector determined that the hot tool room was not staffed during normal operations and that the method for obtaining a contaminated tool could be inconvient to many workers who would have to wait for a tool room representative to grant access.
The clean tool room is located just inside the main security portal some distance away from the hot tool room.
The inspector determined that the licensee plans to staff the hot tool room during peak outage work loads. Access to tools once inside the tool l room was good with bins and shelfs labeled with contents.
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h The. inspector observed licensee employeesL surveying tools and equipment b
- for release from the-RCA. The licensee has a survey table adjacent to the main RCA area 1 acpess and exit portal.
Health abysics personnel are assigned at the survey table to monitor and ' ass st personnel surveying equipment and material leaving the RCA._ Clean trash that is removed from the _ RCA must also pass through the survey station and through a. portal - monitor.
.The' licensee burns clean trash onsite in _ a burn pit.
The inspector-determir.ed that the licensee routinely surveys the. burn pit with a micro R meter.
The inspector reviewed selected burn pit survey results for 1987.
, , During tours of the yard, radwaste, auxiliary, containment and turbine a buildings,, the inspector made independent. radiation survey measurements and verified that -areas were properly posted. -The inspector observed' licensee employees sign out,. response check, and.use radiation monitoring equipment.
< -The clicensee utilized a vendor to clean protective cloth'ing.
Licensee _ procedures' require that the licensee survey approximately: 10 percent of-the protective clothing returning from_ the vendor prior to use.
The , inspector randomly selected various protective clothing from the PC storage room and surveyed the clothing to verify that if was within acceptable reissue limits for fixed contamination.
No violations or deviations were identified.
- 10.~ Solid.RadioactiveWaste(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.
The. inspector reviewed the licensee's method for classifying radioactive wa s te. -- The licensee utilizes generic scaling factors and a vendor supplied computer program to classify its radioactive waste.
The inspector reviewed the licensee's procedure, 08-S-06-11, Classification of Radwaste, Revision 4, dated April 15, 1986.
The inspector reviewed selected radioactive waste shipping packages and . veri.fied that the waste was properly classified.
The 1.icensee has sampled and analyzed its radioactive waste streams and ~ was in the Jprocess of evaluating the data and modifying its waste classification procedures.
The licensee expects to implement its plant specific waste classification program in November 1987.
Through September 1987, the licensee had made 38 radioactive waste shipments for 1987.
All of the shipments contained Class "A" waste.
In 1987 the licensee had generated 8,434 cubic feet (ft3) of radioactive waste containing 3,974 curies, shipped 16,344 ft3 of radwaste containing u_ __
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1,261 curies and had an inventory in September of 1,528 ft3 of.- radwaste containing 2,879 curies.
No violations or deviations were identified.
11.
Transportation.(86721) 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of its plant or other place of use; or.who deliver licensed material to a carrier for transport,. shall comply with' the applicable requirements of the regulations appropriate to the mode of ' transport of the Departaent of Transportation in 49 CFR 170 through 189.
The inspector reviewed the following licensee procedures regarding the transportation of licensee material: 08-S-06-20, Packaging Radioactive Materials, Revision 10, dated July 31, 1987 08-S-06-30, Radioactive Material Shipment Surveys, Revision 7, dated January 26, 1987 08-S-06-50, Loading Radioactive Material, Revision 5 dated January 26, 1987 08-S-06-40, Radioactive Material Shipments, Revision 5,. dated August 6, 1987 The inspector observed the licensee preparations for a dewatered resin radioactive waste shipment.
The inspector observed quality control (QC) personnel complete pre-shipment checklist, health physics personnel providing surveys, and maintenance personnel placing the liner and securing the cask lid.
The inspector reviewed the QC check off sheets; health physics surveys of the liner, cask, and vehicles; and shipping papers for the shipment.
The inspector made independent surveys of the vehicle and cask and discussed pre-shipment responsibilities with QC, health physics and maintenance personnel.
The inspector verified that the shipment was properly labeled and placarded.
The inspector reviewed selected records of radioactive material shipments performed during 1987, and verified that the shipping manifest examined were prepared consistent with 49 CFR requirements.
The radiation and contamination survey results for shipments reviewed were within' the limits specified for the mode of transport and shipment classifications.
The inspector selectively performed independent calculations using licensee records of material radioactive nuclide component and verified that the shipment reviewed had been properly classified.
No violations or deviations were identified.
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' 12. Radiological Controls for Drywell During Spent Fuel Movement (TI 2500/23) During certain spent fuel handling operations, high transient gamma dose rates. can exist in BWR drywell areas due to a lack.of design shielding.
In ~ order to assure-personnel safety from -radiation over-exposures when drywell activities coincide with fuel movement operations, the licensee should take steps.to control access to the drywell during fuel movements
and place administrative controls on the movements of peripheral spent " fuel bundles to preclude excessive radiation exposures.
The inspector verified that the licensee had received the General Electric generic communications on this subject and had takenl action in response to .these notices. During the first refueling outage in the fourth quarter of 1986 the licensee evaluated dose rates in the drywell, containment building, and auxiliary buildings (MARK 3 Containment) during fuel-movement.
Their findings were documented in the Unit 1 Refueling Outage Health Physics Outage Report.
Prior to the outage, the licensee issued Radiation Protection Instruction 08-S-02-75,. Coverage and Control of Refueling Activities, Revision 1, dated September 12, 1986. The procedure.
was utilized to evaluate facility radiation hazards during fuel movement.
The procedure required that the Radiation Control Supervisor be notified when fuel was-to be moved; that communications be established and health physics personnel stand by to measure dose rates in containment, drywell, and auxiliary building; that local area radiation monitors with alarms be installed in the designated locations; that TLDs be installed throughout the' drywell, containment, and auxiliary buildings at designated locations; and that personnel be evacuated from the designated areas.
The licensee moved two fuel bundles which were selected from the center of the core around the reactor pressure vessel (RPV) and through the fuel transfer tube to the spent fuel pool.
As a result of the measurements taken during the fuel movement certain restrictions were imposed.
The 185 foot elevation of the Auxiliary Building adjacent to the fuel transfer canal and containment wall penetration were restricted from access during the remainder of the fuel movement.
In the Containment building, access was restricted on various portions of Elevation 166.
In the drywell, no access was allowed above the 161 foot elevation (height of sacrificial biological shield) nor was access allowed inside the annulus above the fuel region.
The area beneath the cattle chute was also restricted from access unless a health physics representative was present to monitor dose rates.
The licensee utilizes pre-job briefings to instruct workers on the hazards, requirements, and restrictions prior to work in the drywell. The licensee utilizes telephone communications between the refuel floor, the control room and the health physics drywell control point.
A portable fuel chute shield (cattle chute) is used for all spent fuel I moved. out of the reactor cavity.
The cattle chute has six inches of lead and one quarter inch of steel plate on the bottom and three and one half l inches of carbon steel on the sides.
The chute covers the area between l- .. _.._ _ _d____m__ _ - _ _ - _ - - - - - - - _
-- __- - ' . -a-m' . ,y . (.. I-f '
. . I ,, 'theJreactor pressure vessel' flange and the' upper' fuel pool' gate.
The inspector : reviewed the report of. shielding design. calculations ' for the i portable radiation' shield, ' dated' August 8, '1978. - The report calculates . doses:'at 18 feet belowe the' chute.for three conditions, normal fuel. , ! movement, through the. chute (15 millirem per hour (mR/hr)) fuel assembly- . in a Lhorizontal p(osition (250 mR/hr), and with the fuel sitting in a- -slanted' position 100 mR/hr).
The ; inspector ' determined ' that.. licensee. operations procedures do'.not ' ' l require. health ' physics to beLnotified prior to fuel movement nor' do they < addressL ongoing communications with ' the drywell. access point.
The operator procedures do not address ' potential hazards of fuel handling when j the drywell. is occupied or administrative ' controls to ensure spent fuel is H . moved away.from the RPV'when fuel bundles. clear the core.
Licensee '. representatives-in the _-exit meeting.' agreed to implement communication requirements, ' notices. of. potential '. hazards ' in thel drywell: during fuel ovement and controls for= moving. spent. fuel bundles in m
- operating procedures.
The inspector stated that a' review of licensee procedures addressing - fuel--movement safely would be reviewed as :an
- inspector.' followup. item-in future inspections (IFI 50-416/87-23-01).
' No violatio's or deviations were identified.
n 13.
IE:Information Notices (IEN) (92717). 'The inspector determined that the following information notices had been-l ' received by 'the licensee, reviewed for' applicability, distributed to appropriate ~ personnel and -that action as appropriate, was taken.or planned.
87-03, Segregation of Hazardous and Low Level Radioactive Wastes 87-07, Quality Control of Onsite Dewatering, Solidification Operations by .0utside Contractors: I 87-31,' Blocking, Bracing, and Securing of Radioactive Material Packages in , Transportation l l q l
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