IR 05000454/1987034
| ML20235H760 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 09/21/1987 |
| From: | Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235H730 | List: |
| References | |
| 50-454-87-34, 50-455-87-32, NUDOCS 8710010164 | |
| Download: ML20235H760 (13) | |
Text
--
-
a
,
l
..
U. S. NUCLEAR REGULATORY COMMISSION g.
-REGION III.
,.
W
'
i),
- Reports.No. 50-454/87034(DRSS)'; No.-50-455/87032(DRSS)
i
,
.i
.
Docket Nos. 50-454; 50-455
. Licenses No. NPF-37; No. NPF-66'
/
Licensee:
Commonwealth-Edi, son Company.
q
.
Post Office Box 767-
"..
Chicago, IL ~60690'
l Facility Name:
Byron Station, Units 1 and 2 Inspection At:
Byron Station, Byron,' Illinois
- p Inspection Conducted: ' August 24.through September 4, 1987'
.
.
'l l
Inspector:
W. B. Grant
[~M'8 N
)
Date I
i Accompanying Inspector:
M. A. Kunowski
.
I Approved By:
L. R.
reg,- hief
- [~2/"8 7
Facilities Radiation Date
. Protection Branch Inspection Summary Inspection on August 24 through September 4 -1987 (Reports No. 50-454/87034(DRSS); No. 50-455/87032(ORSS))
Areas Inspected:
Routine unannounced inspection of operational radiation protection and transportation activities. including:
organization and management control; training and qualifications internal and external exposure control; control of radioactive materials; ALARA activities;:-a Unit 2 startup survey; transportation of radioactive materials; licensee' action on previous inspection-items;-and licensee performance regarding' person-rem dose during the recent Unit 1 outage.
Results:
No violatic'ns or deviations were identified.
l 8710010164 870923 PDR ADOCK 05000454 G
P.M_
-. - _ - - - - - - _ _ _ _ _ _ -
)
.
-
DETAILS 1.
Persons Contact d
'R. Aken, Radweste Operations P. Andrews, Health Physicist-
- D. Berg, Nucle ar Safety
- W. Burkamper,, Quality. Assurance Superintendent
- R. Flahive, Rtdiation/ Chemistry Supervisor
- K. Graesser,fGeneral' Manager, PWR Division, Ceco T. Joyce, Assistant Superintendent, Technical Services i
M. Kennedy, Technical Staff
'
W. McNeill, Lead Health Physics Foreman
- W. Pirnot, Regulatory Assurance
- R.'Querio, Station Manager
- J. Schrage, Health Physicist, Corporate G. Schwartz, Assistant Superintendent, Maintenance-S. Sober, Henlth Physics, Group Leader
- M. Snow, Regulatory Assurance Supervisor
- J. Snyder, Quality Assurance Inspector D. St. Clair, Assistant Superintendent, Work Planning
- R. Ward, Services Superintendent J. Weitzel, Engineering Assistant
- E. Zittle, Regulatory Assurance
- L.
R. Greger, NRC, Chief, Facilities Radiation Protection Section
- P. G. Brockman, NRC, Senior Resident Inspector The inspectors also contacted and interviewed other licensee and cont ractor personnel during the course of the inspection.
- Denotes those present during the exit meeting on September 4, 1987.
2.
General l
This inspection, whi.ch began at 10:00 a.m. on August 24, 1987, was conducted to examine the licensee's operational radiation protection activities, completion of startup tests on Unit 2, and transportation of radioactive material. The inspection included' numerous plant tours including Unit 2 containment. review of posting and-labeling, radiation occurrence reports, personnel contamination reports, a review of previous inspection findings, independent radiation measurements by the inspectors, and discussions with licensee' personnel concerning the unusually high person-rem for.a first refueling outage dose incurred for the Unit 1 outage.
1 U-___-_--_.
._-__-.___.-______L-.--____-._--___
__- _ _ _ - _ _ _.. _ _
.-
_
_
._ _.
. _ _ - _ _.. -
, _
_
. _. _.
-
_
y
'
g,
-
-
,
.
)
'3.
Licensee Action on Previous Inspection Findings-(Closed)-Open Item (454/86044-02; 455/86039-02): -Additional staffing
]
'
needs oflthe'ALARA group.
'A' health physicist-and a maintenance mechanic'
j ;1
'have been added to the ALARA staff. "In; addition an engineering assistant'
l
.was assigned full-time to. REP (Radiation Evaluation Program).which will-
,' help ALARA activities. ~This item-is< considered closed.
(See Section'10)
outage.
Discussion with licensee personnel; determined that a'large
'
)
(Closed) Ope'n Item (454/87012-01):
High; person-rem for first' refuel.ing:
,
]
portion ~of the high person-rem dose..was attributed.to the unusual i
c
.
activities conducted during the outage.
Based on'these discussions, t
this item is considered closed.
(See'Section 10)
}
-(Open) 0 pen Item (454/87011-01):.. Completion of Unit 2 Startup. Test'
'SV 2.61.83 Radiation' Survey During Power Ascension (100% power). The-
!:
completed test was reviewed; test discrepancies are being' reviewed for-
,
corrective action.
(See Section.12)
'
'
'
4.
Organization and Management Controls
i The inspectors reviewed the licensee's organization and management controls for the radiation protection and radwaste ' programs including.
changes in-the organizational structure and staffing; effectiveness of.
]
procedures and'other management techniques used to implement'these
.
i programs, experience concerning self-identification'and correction of?
l program implementation weaknesses, and effectiveness of. audits of these'
'
programs.
Audits are discussed in Section 5.
Recent Rad / Chem personnel changes include:
l i
A Health Physics (HP) Group Leader transferred.to License Training.
e i
A Health Physicist from the HP Group was promoted to Health Physics
Group Leader.
A Health Physicist and a Maintenance Mechanic'were assigned to the
I ALARA group.
A contract Health Physicist terminated.
- A Engineering Assistant (EA) (Training) was assigned to dosimetry.
l
A Staff Assistant was assigned.to the Radiation Evaluation Program
!
(REP).
!
The persons newly-occupying the above positions are qualified in accordance'with ANSI N18.1 --1971 for the'ir respective positions.
The current staffing of' Health Physicists (HP) appears adequate. 'ThisL
.,
is partially due to the presence of experienced contract HPs. The
'
t inspectors discussed licensee plans for reducing the-dependence on
,
L
--
_-_
- - _ _ -.
'
'
,y
.;
.,
r.
,
,, f
,~
. contractors'and the effect'.of such action on the HP staff and.' program-stability with the Rad / Chem Supervisor and the. Lead Health Physicist.
The effective'.ess of the licensee action will be reviewed during future.
inspections. (454/87034-01; 455/87032-01).
The. inspect' ors're' viewed Radiation 0ccur'rence Reports _(ROR) which'were;
,
1 written in:1987.
There have been'11R0Rs written to date in 1987.
Corrective actions for the RORs have been. completed..The licensee contin _ues to provide sufficient management attention to followup and m
investigation of RORs.
One'open item was identified.
_
!-
5.
- A'ud i t s_.
,
The.. inspectors reviewed audits'ofLthe radiation protection program conducted to date duringL1987.
Extent of th'e audits, qualifications of the: auditors, and. adequacy'of. corrective. actions were.raviewed.
'Two'onsiteq6alityassuranceaudits[oneofRad/Chemprocedures..
laboratory practices, and equipmenticontrol and one of the Radioactive Waste Program were conducted-during. this; period.
Corrective action'on findings appeared to be timely and adequate.
The extent of the audits-and the qualifications of the auditors appeared adequate.
E j
Onsite quality assurance; surveillance' reports'for radiation protection activities, solid radwaste shipments, and ALARA were selectively reviewed.
These surveillance included observationof compliance with
- -
DOT shipping. regulations regarding solid radwaste shipments and
'
radiological protection requirements regarding ALARA radiation' protection
~
activities in containment during the Unit I refueling / maintenance outage.
No significant problems were identified by the auditors who performed the surveillance.
l No violations or' deviations were identified.
6.
Training and Qualifications i
The inspectors reviewed the training and qualifications aspects of the
]
l licensee's radiation protection, radwaste, and1 transportation programs, i
including:
changes in responsibilities, policies, goals,' programs, and methods;. qualifications of newly hired or promoted radiation protection ~
personnel; and provision of appropriate radiation protection, radwaste, l
and. transportation training for station personnel. 'Also reviewed were
_
.
management techniques used to-implement these progem s and experience I
concerning'self-identification and correction of program implementation-weaknesses.
The inspectors discussed Radiation Chemistry Technician (RCT) training with the Radiation / Chemistry Supervisor.
The licensee has recently I
completed an assessment of the RCTs knowledge level.
Based, in part, on
_
.___
-
_ -
= _ _ _ _
-
_ _ _ _
._
_
. -_ _-_ _ = __ -_-_ - -
.
-
,
l l
i that assessment the licensee plans to increase the number of RTCs
!
in 1988 and also to increase the numbers of training days for the RCTs.
The status of the RCT functional split was briefly discussed.
')
l No violations or deviations were identified.
l 7.
External Exposure Control and Personal Dosimetry The inspectors reviewed the licensee's external exposure control and
. personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet I
routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, I
reports,.and notifications; effectiveness of management techniques used to l
implement these programs; and experience concerning self-identification l
and correction of program implementation weaknesses.
l
.
.
l Surveys made in Unit 1 during movement of fuel bundles through the fuel transfer tunnel showed hot spots at the junction of the fuel transfer tunnel ano the containment wall in.the auxiliary building.
A narrow beam of radiation ranging up to 5-6 R/hr was detected as fuel passed through the fuel transfer tunnel into the auxiliary building.
This area is not easily accessible; however, access was administrative 1y controlled by postings and the affected areas were either locked or access prohibited by security guards-during fuel movements.
A permanent modification, either regrouting or hanging external shielding, is being considered to eliminate the radiation streaming.
Status of l
completion of the modification and resulting dose rates will be reviewed l
during a future inspection.
(454/87034-02)
The licensee continues to develop procedures and test equipment for a self-administered whole body TLD program.
Initial efforts began approximately three years ago with the assignment of a staff health physicist to work full-time on the program; in May 1986, a Radchem Foreman was also assigned to the program.
During the development of the TLD program, the licensee has continued to use neutron, whole body, and ring badges supplied by a commercial film badge service.
Badges are changed every two weeks.
According to the licensee, as of the first week l
of September 1987, approximately 1600 individuals were assigned whole body dosimetry.
Technical problems have delayed implementation of the licensee's own TLD program.
According to the licensee, tests were conducted in 2986 on a sample of a set of 6000 TLD badges received for evaluation from a vendor.
The tests, (required by the NVLAP accreditation of the corporate dosimetry program), indicated possible phosphor cross-contamination l
between two adjacent TLD elements and the badges were returned to the vendor.
In 1987, according to the licensee, tests on a sample of a set
,
of 7000 badges indicated that these badges had unusual fade problems.
!
These badges were evaluated at several other Commonwealth Edison plants and similar results were obtained.
Subsequently, the vendor has
_ _ _ _ _ _ _ _ _ _ -
--
,
.
i contracted with a consultant at the University of Michigan to evaluate a sample of the badges and the vendor-supplied TLD reader that has been used by the licensee.
The licensee estimated that the evaluation should be completed by the end of 1987; implementation of the-licensee's own TLD program will be delayed pending resolution of this evaluation.
As part of a corporate-wide effort, the licensee is also evaluating the use of electronic dosimeters and a computer-based dose-tracking system.
The dosimeters read out dose rate and accumulated dose.
Alarm setpoints l
are set by the dispensing RCT or Radchem Foreman using.the computer.
During the recent refueling outage, all individuals in containment were required to wear 'an electronic dosimeter, in addition to a self-reading dosimeter and film badge (s).
The inspectors and the accompanying. licensee staff were provided with electronic dosimeters for the tours of Unit 2 containment (Section 11)'and the fuel transfer tunnel area (Section 7).
The licensee's external exposure control and personal monitoring during the Unit 1 refuel outage are described in Inspection Reports No. 50-454/87012; and No. 50-455/87011.
The inspectors reviewed this area further during this inspection.
Of the approximately l
3000 individuals provided with whole body badges during the outage, 665 were permanent Byron employees, 270 were guards, 150.were
,
l Commonwealth Edison employees not regularly stationed at Byron, and l
the remaining approximately 2000 individuals were contractors.
No
'
individual whole body exposure for the outage, which spanned two calendar quarters, exceeded the licensee's administrative limit of 2250 millirems; extremity exposures did not exceed 25% of the limits in 10 CFR 20.101.
Licensee representatives stated that because of the low extremity exposure for this outage, ring badge usage may be reduced for the next outage.
HPs review daily exposure updates to identify individuals approaching their limit, and contact the appropriate work supervisor and access control personnel when limits are approached.
Updates are maintained at access control.
One open item was identified.
8.
Internal Exposure Control The inspectors reviewed the following internal' exposure control and assessment procedures to determine if they are consistent with 10 CFR 20 requirements, FSAR commitments, and good administrative and health physics practices.
No problems were noted.
BAP 575-1, Revision 1 Radiation Protection Program.
BRP 1000-A1, Revision 3 Byron Station Radiation Protection Standards.
i
.
_ _ _ _
-
.
.
.'
BRP 1310-1, Revision 2 Selection, Issuance, and Control of Radiological Respiratory Protective.
Equipment.
BRP 1310-4, Revision 5 Inspection of Self-Contained Breathing j
Apparatus.
BRP 1310-5, Revision 2 Operation and Use of the Respirator Test Facility.
.BRP 1310-6, Revision 2
' Operation and Use of Air Line Supplied Air Systems.
BRP 1310-7, Revision 2 Charging of Air Cylinders for Self-Contained Breathing Apparatus.
BRP 1310-8, Revision 4 Respiratory Protective Equipment Quality.
,
Inspections.
i BRP 1310-10, Revision 1 Operation and Use of the MSA Filter Resistance Tester.
BRP 1340-1, Revision 3 Personnel Monitoring for Internal
,
Radioactive Contamination.
BRP 1340-2, Revision 5 Whole Body Counting Routine Operation.
BRP 1340-5, Revision 0 Quality Control Program for Whole Body
,
Counting.
I BRP 1340-6, Revision 0 Calculation of MPC-Hours and Organ Dose Based on Whole Bndy County Data from Acute Uptakes.
BRP 1350-8, Revision 0 Calibration and Use of the Eberline Model RAS-1 Air Sampler.
BRP 1350-9, Revision 2 Operation and Calibration of the MS-2/MS-3
'
Portable Beta-Gamma Counter.
BRP 1350-1, Revision 4 Air Sampling of Suspected and Known Airborne Radioactivity Areas.
BRP 1360-2, Revision 0 Containment Air Sampling.During a Refueling Outage.
During plant tours, the inspectors observed filtered auxiliary ventilation systems in use in various cubicles where maintenance work was ongoing, and portable air samplers and monitors in use in the ~ auxiliary building and in the radwaste truck bay during supercompaction (see Section 13).
MPC-hour documentation and control for tritium exposure was maintained for personnel in Unit 2 containment (see Section 11).
- _ - _ - _ _ - _ _ _
o
.
p The licensee's internal exposure control'and assessment programs have been previously described in Inspection Reports No. 50-455/87012; No. 50-455/87011; No. 50-454/85037; and No. 50-455/85041.
No violations or deviations were noted.'
-
9.
Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for. control of radioactive materials and contamination,L including:
changes in instrumentation, equipment, and procedures;. effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination ofisurvey data; effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
The active RWPs were selectively reviewed.
The RWPs contained current survey information.
Approvals and ALARA reviews were included where required.
Administrative exposure limits are used.
Personnel Contamination Reports (PCRs) were reviewed for 1987 to date.
Since the end of the outage, the number of. personnel contaminations have decreased, 225 have been recorded in 1987 through August, 178 PCRs
occurred during the Unit 1 outage.
The licensee tracks PCRs to identify-
!
repetitive violations and violators.
No problems with PCRs or PCR l
tracking were noted.
I 10.
Maintaining Occupational Exposures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and
,
procedures; worker awareness and involvement in the ALARA program; and
'
establishment of goals and objectives and effectiveness in meeting them.
Alsc reviewed were management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
The ALARA group has been strengthened by the addition of a health physicist and maintenance mechanic to the group and the appointment of a full-time person to the Radiation Evaluation Program (REP).
The additions to the ALARA group and to the support program should make the ALARA program more effective.
The initial estimated dose for the Unit One first cycle refueling /
maintenance outage was 390 person-rem.
The actual dose for the outage, which was scheduled for 70 days but lasted 109 days, was 724 person-rem.
No one received a dose in excess of the licensee's administrative limit of 2250 mrem.
The unusually high dose for a first refueling outage appears to have been due to the large number of jobs performed.
These jobs included:
core unloading, eddy current testing, shot peening, tube plugging, and sludge lancing all four steam generators, snubber
_ -- - _ _ _ _ _ - - _ _ _ _ _ _
_ _ _
.
..
,4 b
t inspection, and. inservice. pipe weld'inspectio'ns. fin addition to these norma 1' outage activities the-licensee performed ultrasonic: testing and
. reconstitution of several fuel bundles,.and removed 600 snubbers"and over 200 tons of jet deflector _and pipe' whip restraint supports.from-containment. ' Removal of the snubbers,Jjet defl.ectors, and pipe whip restraints accounted for about 400 of the'725Lperson-rem dose, and was performed primarily as a precautionary measure to: reduce ~ future-person-rem doses due to obstructions and tight' working conditions in containment.
The majority of the.400 person-rem dose accumulated for this work'had not been included'in the initial outage dose estimate.
The licensee scheduled and completed an. unusually large number of tasks during the outage, in all 148' modifications were made and 2750 work requests were completed.
Two-hundred thirty ALARA action reviews.were performed and about 41,000 containment entries were made.
'The dose'from normal. outage activities.without the" snubber, jet-deflector, and pipe whip restraint-removal would have realistically been-about'
325 person-rem.
According to licensee ~personne1' interviewed, lessons learned during this outage pertaining to scheduling, planning, and~morei efficient use.of workers should allow a more dose efficient operation during future outages.
This' was discussed with licensee personnel during
^
the inspection and with licensee management'at'the exit meeting.
One lesson learned from the' outage involved an equal-hour union provision-that granted union contract boilermakers work' hours equal to the nonunion workers brought in by a contractor to perform' steam generator work.
Several union boilermakers apparently unnecessarily spent. " equal-time" on the steam generator platform, a high radiation area, as a result of this equal-hour provision.
When the licensee became aware of this, the union equal-hours workers were not permitted on the S/G platforms or in other high radiation areas; the union equal-hours workers were. assigned work outside'the missile barrier in low dose areas or work'outside containment.
Reviews of RWPs and worker doses determined that the equal-hours practice was not dose significant; it.was, however, not ALARA..This matter was discussed with licensee personnel during the inspection and with licensee management during the exit meeting.
This matter also. identified a potential weakness with the licensee's RWP practices, in that the union boilermakers were allowed to enter containment on the steam generator RWP when they weren't assigned by the licensee to work under that RWP.
This matter will be reviewed further during a future inspection.
(454/87034-03)
No violations or deviations were. identified.
11.
Surveillance; Unit 2 Containment Tour l
l During an unscheduled outage to repair a hydrogen leak in the Unit 2 generator (in the Turbine Building), one of the inspectors accompanied an RCT on a tour, of Unit 2 containment.
The RCT provided HP support to several' crews. performing minor maintenance in containment while the leak in the generator was being repaired.
During the repair'and the minor maintenance, the reactor was in the hot shutdown mode.
Personnel' entered
l
.
.
.,
.
.,
,
and exited containment through the personnel. hatch and dressed out in-cloth coveralls with beta eye shields and electronic dosimeters.
Respiratory equipment was worn by maintenance personnel as required by the.
-location or type of. repair work.
Housekeeping and postings inside'and'
outside.of the reactor: missile' barrier and outside' of containment at the stepoff pad were. acceptable.1 ALARA personnel tracked dose accrued by personnel.
Requirements.and guidance for containment. entry are described.
in the. licensee"s Procedure BAP 1450.1; Security. personnel stationed at the entrance to;the equipment hatch controlled personnel entry and egress per BAP 1450-T2, Containment Entry - Checklist.
No violations or deviations were identified.
12.
Unit 2 Startup Tests The inspectors reviewed the results of the 100% power startup survey, completed in mid-1987,
SU 2.61.83 Radiation Survey During Power Ascension. conducted July 9-14, 1987, at 90 - 100% power.
Test results were reviewed.
Thirty-three, 30 neutron and 3 gamma, Radiation Base Points (RBPs) exceeded the acceptance criteria.
.Some neutron dose rates exceeded the FSAR acceptance criteria by as much.
as 40. times (200 vs 5 mrem)..All of the excessive dose rates are within the containment building.
A Corporate engineering study.(AIR-6-85-0020) is being l-conducted to resolve these discrepancies.
Interim
'
precautionary measures have been taken to control radiation exposures within containment.
This matter will be reviewed during a future inspection.
l (455/87011-01)
One open item was identified.
13.
Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including:
determination whether changes to equipment and procedures.were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process. control and quality assurance programs; adequacy.of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses.
Operation of a mobile " super-compactor". was observed.
The inspectors reviewed the status of the radwaste Volume Reduction System (VRS).
This system is described in Inspection Reports No. 50-454/86034; and No. 50-455/86029.
Mechanical problems continue to prohibit operation of the VRS. Maintenance and engineering staff continue to work on these problems.
A modification to bust clods or l
1
- _ _ _ - _ _ _ _ - - -
- - - _ - _ -
___- -_ _-___ -_ _ _
. - _ _ _ _ _ _ _ - _ _ - - _ _ - - _ _ - _ - -
- -
<--a m
y-g c.
,
,
.
/h.
'
' ' ~.
j
'
y } ' )fjr ' {l,
,
} Qh
'
f, u->
a f
Y
,
,
Q(
'
1 -
s a..
,
-
o
,
y.
,
j lumps. that are generated 'during the @cinerationtand evrperation stages has been cornplated.
lesting of the 'ilod buster is:rixpe;ted to be;.
_
j completed in la% Sip.
'
,T.
- {,,
' d
'
7<
' Licenso'e represena'.1tives And" records indicate: that' in:IM6 fthe licensee -
'
'
y J
L
,
.
.
,.
>
"
>r
. i
,d' }
made'seven shipments of Dry Active Waste (DAW) and 31' shipments of.
filters and dewatered/ solidified sludges and resins.-
In 1987 to date,.
,.
if l'
thr' e' shipments of ' DAW?and 27. shipments.of flly+ ring and deminerali. zing :
e
$.
i tr.edia were made. Owing'to problems with the fadwaste evaporators,
>
evaporator bottoms have not been generated singa October 1986.. Compacted
,
.
and m ompacted DAW is usually. packaged in F@ gallon drums;~ occasionally,
_
[ g.
.
uncorrhat.ted DAW is packaged'in retal bfns (volume of 96,ft8). : An omite.
i
'(
ve @ r representa'.tvo performt dewar,ering/ solidification of filtering.and s
derrineralizatior, waute 10enport supplied matal liners and high. integrity containers.
Licensr4 QA/QC personner verify that the dewatering /
i
- solidification meet?hRC prio Onial dite requirements.,
s
.
y
/ o
!~
.;
,
During' this.insp'edion and once in July 1987, the J11censee has had l
I 55 gallon drums oVDAW compacted in a vendcr supplied " super-compactor".
"t
. During operation,' the reinforced semi-trailer that houses the'
,/.
I super-compactor is parked in the licensee's radwaste truck bay and its
,I J
included in a ropedroff coitaminadon area.
The vendor's onsite
!
J, representative and the licensee's\\hadwaste operations foreman coordinate, worate the suParp)the tiree vendor representatives who accompry and
?icensee staff and i
!
ppcctor. _ Licensee. staff retrieve uncompacted' barrels
',
of WAW from stora pjand' place'them at the stepoff pad o pt the trailer.
.
Within,the ropet off area, a vendor representative plafes.the drsm,on a
,
-
mqcha&O. ToadM wHch hoists the drum from ground levekto a small n
trackway,n'thytreiler.
In the trailer, another worker actuates a ram
,
that pu;hes thq barfel-into a metal cylinder.
The cyllir. der has' internal
'
dimensions that~are slightly larger than those of the W gallon drums
(A cylind/r Mized for 52 gallon drums also is available). With a barrel inside, the,cylinchc pivetis to a position aligned with the main ~ ram.
The
,
main ram compacts the barrel against a metal piste, with'the metal'
.
cylinder restricting lateral displacement. of the barrel. ' After compaction is completed, the" ram is withdrawn.and the cylinder pivots back to a potition' aligned with the.. loading ram..The loading ram is-then used to j
,
I-f'
push the flattened. drum o1t of the cylinder and on to a slide, which
.
' directs the drurn te a pistform near ground level.. The third worker then s
s uses a magnetic boist tu place the flattened drum in an 85 ga11on l.
overpack drum.
Aftir thefoverpack drum is filled and_capp'ed, it is pushed to tha ed(s 'of;the roped-off area where a licensee representative in a front-eud h def yetrieves the barrel.
An RCT then surveys the drum to ensure theta contamination and exposure levels are below ' regulatory and procedural limits.
The drum is then set aside to be loaded on a truck for g
i eshipment to'the burial s1te.
,y t/
' j,f During compaction, airburne radioactivity was' limited by a HEPA filter
,
f equipped ventilation system opt rating in the trailer.
The licensee
mor.itored airborne radioactivity with a portable air sampler.
To contain contamination, plastic sheets were laid on ground-level walking surfaces
x and on sections of the treibr.
Vendor representatives working in the
.
$h h qi
4
"
l N
a:
y.f#y
,
\\U hfbU
."
.
> V.,
,
,.
,
__._ _ __ _.- -_
.
_.
-_- _-_-.
_ _-
p-
' '-
,
,4
_
y
...
,
,
,
i
.
l
'
'
.
,
. R(roped-off area dressed out in cloth coveralls, rubber gloves.and. shoe-
.
covers, and.' plastic'faceshields.
After completion of the compacting,'the
.j
'
trai.ler and truck bay were surveyed and decontaminated as needed.
,
. Licensee; representatives stated,that'31. drums were compacted in July
{
,
1987c and approximately!400; drums were compacted'in August and early
.J September 1987, including drums.containing much-offthe~ DAW generated
<
- during the recent Unit 1. refuel' outage.
The licensee stated that-l L
because of the barrel compactor, two to three 55 gailon drums could-
.!
L usually be' packaged in one 85 gallon overpack drum.
The amount of-
ll
. compaction obtained apparently.is limited by the resiliency of the.
'
' DAW in the. barrels.
Vendor, representatives stated that because of the resilience of.certain plastics, lids.of compacted barrels containing y
plastics may pop off and/or the seams on the bottom'of barrels containing.
plastics may split.- The: inspectors observec: this problem during compactor
'
,
operations.
Licensee representatives stated that an effort will be
mede to separate plastic DAW from other DAW during future sorting-of DAW J
anj ffiling of S5 gallon drums.
Classification and shipping of solid radwaste and super compaction.of DAW appear to have been performed in accordance with regulatory requirements-and. licensee procedures.
'
f -
No violations or deviations were identified.
14.
Transportation of Radioactive Materials The inspectors reviewed the licensee?s transportation of radioactive materials program, including determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program;,
.
determination if there were any transportation l incidents involving licensee shipments;. adequacy ~of' required records, reports, shipment l'
documentation, and notifications; and experience covering : identification and correction of programmatic weaknesses.
.
.
i Records of radioactive material shipments made during 1986 and 1987 to i-date'were reviewed.
In 1986, the licensee made 38 shipments of l
radioactive waste as Low Specific Activity (LSA) materials on exclusive use vehicles.
In 1987 to date, 30 such shipments were made.
Additionally
,
in 1986-1987,.several radioactive process samples were shipped as' excepted radioactive material, limited quantity, to contractor laboratories.
No
problems with shipment documentation and quality control / assurance were
'
identified.
Shipments of radioactive material appear to have been made in accordance with the' requirements in 10 CFR 61, 49-CFR 170-179, and'the-licensee's main transportation procedure BRP 1520-1, Revision 4,.0ffsite Shipment of Radioactive Material.
!
No violations or deviations were identified.
.
..
i l.
,.
--
_ _ _ _ _ _ = _.
-
-
. - - - -...
- _.
e-
.
-I 15.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
j on September.4,1987.
The. inspectors discussed the scope and findings of
]
the-inspection.
The inspectors also discussed the likely informational q
content of the inspection report with regard to documents or processes.
d reviewed during the inspection.
The licensee identified no such j
documents / processes as proprietary.
In response to certain matters i
discussed by the inspectors, the licensee:
I k
a.
Acknowledged the inspector's comments concerning the high person-rem l
dose for the Unit 1 outage.
.
b.
Acknowledged the inspector's comments concerning the ALARA group j
staffing.
{
-l c.
Acknowledged the inspector's comments concerning the union agreement j
for equal hours and the effect on ALARA.
'
l
i i
I
$
1
!
l
l
. - - _ _ _ _