IR 05000529/1986013
| ML17299B248 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/15/1986 |
| From: | North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17299B247 | List: |
| References | |
| 50-529-86-13, 50-530-86-10, GL-85-08, GL-85-8, IEIN-85-092, IEIN-85-92, NUDOCS 8605200332 | |
| Download: ML17299B248 (28) | |
Text
8605200332 860515 PDR ADOCK 05000529
PDR U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528, 50-529/86-13 and 50-530/86-10 Docket Nos.
50-528, 50-529, and 50-530 License Nos.
NPZ-41, NPF-46 and CPPR-143 Licensee:
Arizona Public Service Company P.
O.
Box 21666 Phoenix, Arizona 85836 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2, and
Inspection at:
Palo Verde Site - Wintersburg, Arizona Inspection Conducted:
April 14-2
,
1986 Inspected by:
H.
S.
orth, Senior Radiation Specialist Approved by:
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P. Yuhas, Chief Facilities Radiological Protection Section Date Signed M/S d'g Date Signed
~Summa Ins ection durin the eriod of A ril 14-25 1986 (Re ort No. 50-528 50-529/
86-13 and 50-530/86-10 inspections findings, occupational exposure during extended outages, Unit-2 preoperational testing of radiation monitoring system, transportation, review of licence reports, followup on Information Notices and Generic Letters, and plant tours.
Inspection procedures addressed included:
30703, 25565, 25401B, 83729, 86721, 92700, 92701, 92702, and 92705.
Results:
In the seven areas examined, no violations or deviations were identified.
One unresolved item relating to classification of a waste shipment Mas identifie f
DETAILS Persons Contacted AJ VJ
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Bynum - Plant Manager Bayless - QA Engineer Bradish - 'Incident Reporting Supervisor - Compliance Brown - Manager, Radiation Protection and Chemistry Cederquist - Manager Chemical Services Doyle - Unit 2 Radiation Protection Supervisor Drinovsky - QA Engineer Fountain - QA Engineer Gross - Regulatory Inspection Supervisor - Compliance Hackbert - Quality Audits Supervisor Hillmer - Radioactive Materials Control Supervisor Johnson - Unit 2 Chemistry Supervisor Kelly - Quality Engineer Lantz - Radiation Protection Support Supervisor Mann - Corporate Health Physics/Chemistry (Deer Valley)
Morita - Licensing Oberdorf - Unit 1 Radiation Protection Supervisor Penick - Quality Monitoring Supervisor Perkins - Radiological Services Manager Phillips - Unit 2 RMS Engineer Prawlocki - Senior QA Engineer Russo - Manager, QA Audits and Monitoring Schlag - Radwaste Support Supervisor Selman ALARA Supervisor Shriver - Manager Compliance Voboril, Lead Radiation Monitoring System Engineer Vorhees, Manager Nuclear Safety Warren, Unit 1 Chemistry Supervisor White, Senior Quality Audits Engineer Zeringue, Manager Technical Support Denotes attendance at the April 25; 1986, exit interview.
In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's staff and contractor employees.
Corrections Inspection Report No. 50-528, 529/86-08, 50.-530/86-05, the reference (50-528/86-08-06)
at the end of the first paragraph at the top of page
should be (50-528/86-08-07).
Licensee's Action on Previous Ins ection Findin s (0 en) Enforcement (50-528/85-22-01)
Violation related to the failure to tully implement the requirements of Technical Specification (T.S.) 6.8.4.e which required that a Post-Accident Sampling program be established, implemented and maintaine r T
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The procedures identified in Inspection Report No. 50-528/86-08 had not been approved and implemented.
The Unit 1 PASS was out of service at the time of the inspection.
The matter will remain open pending the licensee's completion of action.
(Closed) Followu (50-528/84-57-02)
Inspector identified item relating to access controls applicable to
.incore detector space below reactor vessel.
The locked, posted door to the space below the reactor was observed during containment tour.
Procedure 75RP-9RI01, Ent to the Incore Detector Chase, Rev. 2, 12/20/85, provides that access and key control were vested in the Unit Radiation Protection Supervisor.
Key and access controls were verified with a Shift Supervisor and the Unit 1 Radiation Protection Supervisor.
No concerns were identified.
This matter is considered closed.
(Closed) Followu (50-528/85-22-03)
Matter related to the maintenance'f records of surveys of tools and equipment leaving a potentially contaminated area.
Quality Monitoring Section Monitoring Report No. SM-85-0775, September 13, 1985, verified that tools and equipment leaving potentially contaminated areas were surveyed and that records were maintained.
This matter is considered closed.
4.
Occu ational Ex osure Durin Extended'Outa es A.
Audits and A
raisals The organization of the licensee's Quality Audits/Monitoring program was described in Policy No.
P 202.00.00, Rev. 2, 2/5/86, Organization and Responsibility Policy.
The Manager, Quality Audits/Monitoring reports to the Director/Assistant Director, Corporate QA/QC, and is responsible for the audit and monitoring programs.
The Manager's activities were supported by the staff and supervisors in, the areas of audits, monitoring, test monitoring and document review.
The PVNGS FSAR Volume XVI, Chapter 17, glossary defines monitoring as the review, observation or inspection for the purpose of verifying that an action is accomplished as specified.
Discrepancies identified during audits and monitoring may be documented in either Corrective Action Requests (CAR),
a formal document requiring a written response, or Quality Assurance, Observations (QAO) which are less formal and more capable of prompt resolution.
In addition to audit and monitoring activities, the Quality Monitoring group maintained a Quality Monitoring Turnover Log during the Unit 1 outage.
The Log was examined for the periods March 9-19 and March 31-April 16, 1986.
The following monitoring reports, related to radiation protection, were examined:
Monitorin Re ort SM-86-0144 SM-86-0117 Date 3/27-28/86 3/14/86 T~oics Radwaste Rad Protection and AIARA
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SM-86-0137 SM-86-0134 SM-86-'0160 SM-86-0159 SM-86-0157 SM-86-0152 SM-86-0156 SM-86-0145 SM-86-0195 SM-86-0098 SM-86-0108 SM-86-0111 SM-86-0112 3/20-26/86 3/12/86 3/14/86 3/18/86 3/19/86 3/22/86 3/12/86 3/22/86
.4/4/86 3/9/86 I
3/11/86'/14/86 3/11-13/86 checklist Contamxnatxon Control Radiation Protection Program checklist REP log and completion REP checklist RAM contamination control checklist RAM storage and control checklist Radiation Protection Program checklist (4 of 49 items addressed)
Approximately 60 REP expir'ation dates examined (one found outdated by about
hours)
REP checklist (18 of 20 items
,addressed)
Radiation Protection Dosimetry checklist Radiation Protection Program
'checklist (32 of 49 items addressed)
Improper use of Protective Clothing hoods Radiation Protection ALARA Note:
Checklists used in monitoring activities were procedure based and were used with current procedures during monitoring.
Checklists identify major topic areas of procedures to be addressed.
Audits may be scheduled or unscheduled.
Annually a
~Cor orate ualit Assurance Audit Schedule is prepared based on T.S.
requirements, commitments and FSAR Section 18.
The audit schedule identifies the audit matrix which specifies the audit subject area, requirements, scope, procedures and reference documents.
The report of two audits related to radiation protection, one unscheduled and one scheduled, were examined.
The unscheduled audit, QA Audit No.85-016,, QA Document No. 85-(AM-0463/CNR, May 17-June 4,
1985, addressed programatic and"procedural controls prior to criticality.
Two CARs relating to REP documentation and documentation related to training of radwaste personnel had been closed.
Five gAO were issued on which action had been completed.
Scheduled (}A Audit, Report No.85-021, conducted July 1, 1985, addressed training and qualification; inplant monitoring program, ANKARA program, control of SNM, radiation protection program, surveillance of radiation monitoring instruments and sealed source contamination and radiation protection measuring and test equipment.
The audit resulted in the issuance of 5 CARs, all of which had been closed, 7 gAOs with a'cceptable responses and 3 QAOs closed during the audit.
In addition, gA Audit Report No.86-006,
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Safet In ection S stem-Unit 1, included ALARA.
There were no findings in the ALARA area.
The licensee's audit and monitoring programs appeared to be probing and effective in identifying problem areas and achieving corrective action.
~Chan ea In response to concerns, identified in tracking reports of surveys associated with REPs, the licensee was implementing a survey records management system.
Surveys were logged and issued sequential numbers.
Initial and subsequent surveys were recorded on REPs.
The licensee was preparing to implement an in-house whole body counting capability (reference section Internal Ex osure Control).
As a result of experience gained during the outages, the licensee was considering the redesign of the 140 foot elevation access control area.
With peak containment entries of up to 1,400 per day, a need to improve the effectiveness of operations had been identified.
Plannin and Pre aration The radiation protection staff participated in all phases of outage planning and scheduling.
Initially, some organizational elements lacked understanding of the radiation protection and ALARA role in the outage.
Strong and continuing support of radiation, protection by plant management was effective in resolving initial difficulties.
Contract radiation protection technicians were supplied by three firms.
The contract staff started at 45 technicians, peaking at 75 senior and 43 junior technicians and had been destaffed to about'5
't the time of the inspection.
Contract personnel were assigned to all containment work in order to provide"the most experienced work force available.
ANPP radiation protection personnel were cycled through containment to gain experience.
.The plant radiation protection staff had'ead responsibiIity on the LPSI,pump seal replacement which had not been performed at =the time of the inspection.
t The licensee's plant radiation protection staff consisted of a supervisor, three lead and 14 technicians.
Duri.ng the outage, one technician was temporarily upgraded to lead.,
The unit, radiation protection staff worked 10-12 hour shifts during the outage.
Radiation protection management had requested a budget for an outage organization to support 'outage work consisting of a supervisor and two lead technicians per plant.
No response to the 'budget request had been received at the time of the inspection.
The licensee reported that supplies of instruments and equipment were adequate.
During the outage, a permanent breathing air system was being installed.
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Maintainin Occu ational Ex osures ALARA The ALARA staff of three ANPP and four contractors was augmented with three technicians for the outage.
An ALARA staff of one supervisor, five engineers, four technicians, and one aide had been proposed as a budget request but not acted on at the time of the inspection.
The AIARA staff participated in all outage planning meetings with Outage Management Group (OMG), operations engineering, station services, and radiation protection.
Planning for the outage began in October 1985.
Eleven HEPA ventilation systems, up to 2,000 cfm were in service in Unit 1.
Special shields were designed and used for the reactor coolant pump work which significantly reduced exposures.
AIARA reviews were performed whenever radiation protection REP estimates of exposures exceed one manrem.
In addition, when exposures on an individual REP exceeded 0.75 manrem, an ALARA review was performed if not performed earlier.
The estimated exposure for the Unit 1 outage was 136 manrem.
At the time of inspection with most work complete, 67 manrem had been accumulated due to, the outage with a facility total for 1986 of 80-90 manrem for Unit l.
Licensee management had approved the inclusion of an awards program for exposure reduction along with existing programs for monetary savings and safety.
The APS wide program was called the "Idea Line" and provides for awards of up to
$500 and a letter of appreciation.
Contractor technicians were selected from groups of resumes
"
(verified as necessary)
provided by different contractors.
Selected technicians received Site Access Training and Radio'logical Work Practices training.
In addition, a specialized qualification training program was prepared which addressed ANPP instruments, procedures and posting practices.
In the absence of mock ups for special task training, work or training on other PVNGS units was substituted.
Steam generator eddy current training was performed on Unit 3.
This task, originally scheduled for Unit 1, was later canceled.
Of the crews performing the reactor coolant pump work on Unit 1, 40/ had performed the same work on Unit. 2 prior to initial criticality.
With respect to the LPSI pump seal replacement, a Unit 2 LPSI pump seal had been replaced prior to criticality.
ALARA monitored and prepared a photographic record of the Unit 2 work in support of planned work on Unit 1.
External Ex osure Control The licensee's TLD program had not been changed from that, previously described.
The TLD program was NVLAP certified.
At the time of the inspection, approximately 4000 TLDs were in use.
TLDs were
, processed on a quarterly basis with self indicating dosimeter (SID)
measured exposures accumulated between TLD reading periods.
SIDs were read and recorded by dosimetry clerks.
SID measured exposures
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of less than 7 mrem were recorded as 0 mrem while those in the 7-10 range were recorded as 10 mrem.
Using this approach during the first quarter 1986, the average SID measured exposure was 63 mrem while the TLD measured exposure was 61.8 mrem. It was found that. in less than 20 cases did this technique underestimate TLD measured exposure by 10-25 mrem when 30,000 SID readings were involved.
In the case of employee terminations and anomalous SID values, TLDs were processed promptly.
During the first quarter 1986 only 42 whole body TLDs were processed out of normal sequence while several hundred extremity TLDs were read.
An IBM-PC was used to track SID and TLD measured exposures.
SID readings were entered three times a
day.
Daily cumulative exposure reports were prepared and supplied to managers and access control points.
Forms NRC-5 were manually updated quarterly.
Randomly selected current and terminated personnel files were examined.
Forms NRC-4 were complete and signed, NRC-5 forms were current and termination letters were issued on a timely basis.
As of April 21, 1986, 1,045 badged persons had received exposure, totaling 93.876 rem (37.378 rem to ANPP personnel and 56.498 rem to contractor personnel).
The maximum individual exposure during first quarter 1986 was 763 mrem with approximately 15 individuals in the 200-400 mrem range.
During 1985, 304 individuals accumulated a
total exposure of 14.102 rem.
Internal E
osure Control The licensee had just completed installation and one week training (7 persons and one ANPP instructor)
on two Canberra whole body counters.
The system included both a "Eastscan,"
60 second standup and an "Accuscan," scanning bed type counter, each equipped with 4 X 4 X 16 inch NaI (Tl) crystals.
The "Fastscan" incorporates two such detectors.
The two systems have separate terminals but share a
Microvax computer and printer.
The systems will not be declared operational until procedures have been prepared.
The licensee plans to incorporate the Oztec chair counter which was part of the CRACS system into the whole body counting complex.
A Helgeson mobile, bed type, scanning, whole body counter was operable and on site.
The dosimetry group maintains MPC hour records based on Unit supplied MPC hour tracking for individuals.
No individual had exceeded
MPC hours in seven days.
The daily report'prepared by dosimetry, reports individual MPC hours, the remaining permissable MPC hour exposure and quarterly and yearly MPC hour totals.
Control of Radioactive Materials and Contamination Surve s
and i~lonitorin During the outage routine surveys were performed by ANPP personnel while containment surveys
.were performed by contract technicians.
Surveys were generally recorded on floor plan maps of the facility.
Current surveys were maintained in a log book by map number.
Earlier survey results were filed by map number.
In addition, a log was maintained of surveys which noted map number, location, time and
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.date, REP number, air sample number and remarks.
Randomly selected survey records were examined.
No deficiencies in form or content were identified.
All surveys records were reviewed by a lead or senior ANSI qualified technician.
In the case of surveys performed in support of REP issuance, copies of the surveys were provided to the REP room, technician covering the work, satellite access control point and on occasion the job site.
Survey records remain in the Unit approximately one month before transfer to document. control for, microfilming and permanent storage.
Procedure 75AC-9ZZ12 provides for documentation of radiological problems on Radiolo ical Controls Problem Re orts forms.
The reports document the event, individual s and/or equipment involved, immediate corrective action taken and provides for response to the Radiation Protection Supervisor within 10 days by the supervisor responsible for the personnel and/or equipment which caused the problem.
Personnel contamination events were documented and initially evaluated at the technician level.
Contaminations at a
level of less than 10,000 dpm (1,000 cpm) per frisker probe area (17 cm ) which involve no facial contamination were decontaminated, documented and not subject: to further evaluation.
At levels greater than 10,000 dpm or where facial contamination was present, the report was referred to the dosimetry group for exposure evaluation.
The Unit 1 operational radiation protection staff reported that during 1986, 53 personnel contaminations had occurred.
Skin dose calculations are performed for all contamination of 20,000 cpm/probe area (17 cm~) or higher.
Most were less than 40,000 dpm/probe area and were successfully decontaminated to less than 1,000 dpm or were limited to clothing.
The highest level observed was 500,000 dpm/probe area.
In this case decontamination was effected in approximately 20 minutes.'he calculated skin dose was 50 mrem.
The individuals TLD was contaminated during the same event and required about the same decontamination time.
The TLD indicated dose was 50 mrad.
Recurrent contamination events involving a single individual were identified and evaluated from 'the standpoint of radiological work practices or the need for corrective action or retaining.
Cobalt Particle E
osure On March 18, 1986, a 3echtel pipefitter frisking out of Unit 1 containment caused an alarm on the Eberline, PCM-IA, automated, computer controlled frisker.
Subsequent investigation by the licensee identified a minute particle (approximately 0.08 mm X 0.02 mm) between the worker toes inside his shoe.
Gamma analysis established that it contained approximately 0.2 microcuries of Co-60.
No samples of contamination from the employees'ork place were exclusively cobalt isotopes all being contaminated with antimony isotopes.
The licensee considered the possibility that contaminated Mexican rebar was involved when it was learned that the worker had cut rebar when he built his own home recently.
The licensee surveyed the worker's residence, tools, and washer/dryer with negative results.
Subsequent analysis of the particle identified trace quantities of Co-58 in addition to CO-60.
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licensee performed a conservative dose calculation and assigned a
dose of 1,360 mrad to the extremity as a result, of the 5'-hour exposure.
The origin of the essentially pure cobalt particle was not identified.
No violations or deviations were identified.
Unit 2 - Prep erational Testin Radiation Monitorin S stem (RMS)
Condition (10),
Su lement No.
1 to NUREG-0737 Re uirements, of license NPP-46 specifies that
"APS shall complete the items listed in Attachment 2" of the license.
Item (c) of Attachment 2 specifies that,
"APS shall implement the provisions of Regulat'ory Guide 1.97, Revision 2, in accordance with the schedule'provided in ANPP Letter 33965 dated November 8, 1985."
The letter, ANPP-33965, in attachment 3 provided an implementation schedule for radiation monitoring system (RMS) components among other items.
A letter, ANPP-34129, dated November 29, 1985, entitled Justification for Interim 0 eration Related to the Radiation Monitors, further clarified the schedule and committed to:
(1) have T.S.
required monitors operable prior to initial entry into the mode for which they were required without entry into a T.S. action statement; (2) make Regulatory Guide 1.97 monitors operable in accordance with the
'ommitments contained in letter'NPP-33965; and (3) make monitors, not required by T.S. or discussed in letter ANPP-33965, operable in accordance with an attachment to letter ANPP-34129.
The licensee's inability to have the m'onitors operable in a more timely fashion was occasioned by a change in the preoperational testing program.
Initially preoperational testing required that, monitors be tested and calibrated by the preoperational testing organization prior to being handed over to the operation's group for surveillance testing (recalibration) prior to being placed in service.
Part way through the preoperational testing program, the responsibility for RMS testing was transferred to the operations group for system validation, verification and performance demonstration and surveillance testing (calibration) prior to being placed in service.
The change in preoperational testing program and a shortage of spare parts caused the delay.
During the inspection additional clarification of the interpretation of the commitment, to have specific monitors operable prior to initial entry into a mode for which they were required without entry into a T.S. action statement, was required.
The clarification was achieved by the licensee's submission of a clarification letter to NRR.
Specific monitors were selected for review:
Monitor Control Room Ventilation Monitor (RU-29)
Machine Area Monitor (RU-33)
Power Access Purge Exhaust Monitor (RU-37)
Ventilation'Monitor Normal Range (Plant Vent)
(RU-143)
'ontainment High Range Area Monitor (RU-149)
All Refueling Not Specified When Purge Used All 1, 2, 3,
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Procedures reviewed:
73PE-2SQ01 RMS Minicom uter Software/Communicative Verification, Procedure, Rev.
73PE-2SQ02 Post Accident Radiation Monitorin Test Procedure, Rev.
73PE-2SQ03 Radiation Monitorin S stem Test Procedure, Rev.
73PE-2SQ04 Safet Related Radiation Monitorin Test Procedure, 36ST-9SQ01 36ST-9SQ03 Rev.
Radiation Monitorin Monthl Functional Test Procedure, Rev.
Prior to Pur e/Release'adiation Monitorin S stem Functional Test Procedure, Rev.
36ST-9SQ04 Radiation Monitorin Quarterl
'Functional Test, Rev.
36ST-9SQ05 Radiation Monitorin Calibration Test for Baseline Process Monitors, Rev.
36ST-9SQ06 Radiation Monitorin Calibration Test for Baseline Area Monitors, Rev.
36ST-9SQ07 Radiation Monitorin Calibration Test for New Sco e
Process Monitors, Rev.
36ST-9SQ08 Radiation Monitorin Calibration Test for New Sco e
Area Monitors, Rev.
Test results for the selected monitors were examined and verified to hav'e been completed, reviewed and approved by the Test Result. Review Group (TRRG) prior to entry into the mode for which they were initially required.
The status of testing of all monitors was examined.
No failures to satisfy licensee's commitments were identified.
No violations or deviations were identified.
A.
Audits and A
raisals Audit No.86-014, Process Control Pro ram (Radwaste Mana ement)
conducted April 7-24, 1986, was completed during the inspection.
As a result of the audit, seven draft CARs had been prepared and discussed with representatives of the radwaste group.
Objections raised by the radwaste group, relating to the validity of certain of the CARs, were under consideration by the Quality Audits organization.
The draft CARs resulting from the audit were discussed and reviewed with the Quality Audits staff.
Item 1.
Requirements
CFR 71.12(c)(1),
GFR 173.475(c),
and
CFR 173.475(e)
relate to documentation and quality control in the preparation. of packages for shipment.
The audit found that while all required documents were available, a
controlled methodology for implementation of Certificate of Compliance requirements was not in place.
Item 2.
Radwaste Guideline 27, Sam lin of Radioactive Filters,
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specified that all filters were to be sampled.
The CAR was based on failure to follow the Guideline in that all filters were not sampled.
Item 3.
Procedure 75RP-lZZ02, Rev.
0, Packa ed Radwaste Classification, requires recording the contents of waste drums on a form attached to the procedure.
The drum contents were recorded in a log which was to be used in completing the form at a later time.
Item 4.
CFR 173.474(A)(l) and (2) address requirements for quality control in the construction of packages.
No objective evidence was available to substantiate that the requirements had keen satisfied.
Item 5.
Procedure 75RP-9ZZ57, Rev. 1, Packa in Markin and Labelin of Radioactive Material, specifies that a special procedure shall be written if not covered by the existing procedure.
The procedure addressed only compaction and solidification of waste.
Shipment 85-SH-37 was neither compacted or solidified and no special procedure was prepared.
In addition, the supporting documentation for the shipment was incomplete in that it did not provide sufficient data to reconstruct. the details of the shipment classification.
As a result of this finding, radioactive waste shipments were voluntaril'y 'suspende'd b'y the Manager, Radiation Protection and Chemistry.
Item 6 ~
Low-Level Waste Licensin Branch Technical Position on Radioactive Waste Classification, Rev.
0, May 1983, Section 3, Concentration Volumes and'Masses, notes that
"Waste classification volumes of'artridge filters stabilized by emplacement within high integrity contai'ners should be determined as calculated over the volume of the cartridge filter itself rather thorn the gross, volume of the container."
For shipment 85-SH-37, the assumed volume of the contents of the high integrity containe'r rather than the volume of the individual,, filters w'as used for waste classification.
Item 7
~
CFR 61.55(a)(8), Determination of Concentrations in Waste, states in part,
"The concentration of a radionuclide may be averaged over the volume of the waste, or weight of the waste if the units are expressed in nanocuries per gram."
The specified volumes and weight of the waste in shipment 84-SH-37 could not be verified as correct from the data available'he licensee audit appeared to be thorough and probing.
Action with respect to corrective action on the CARs will be examined during a subsequent inspection (50-528/86-13-01).
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Procedures Iicensee's procedures addressing radioactive material transportation
.
were examined, including:
75AD-9ZZ04, Rev.
1, 12/5/85, Shi ment Recei t and Stora e of Radioactive Materials; 75RP-9ZZ57, Rev.
1, 10/30/84, Packa in Markin and Labelin of 'Radioactive Material; 75RP-9ZZ59, Rev. 2, 10/4/85, Shi in of Radioactive Material; 75RP-1ZZ02, Rev. 0, 10/30/84, Packa ed Radioactive Waste Classification; 75RP-lZZOl, Rev.
1, ll/14/85, Solidified Radioactive Waste Classification.
Between December 13, 1985, and 'March 25, 1986, a total of 14 radioactive waste shipments had been made to U.S. Ecology, Richland, Washington.
Records relating to 6 shipments were selected for review.
Shi ment No.
85-SH-029 85-SH"035 85-SH-036 85-SH-037 86-SH-038 86-SH-9 Shi ment Date 12/13/85 12/20/85 12/28/85 12/28/85 1/3/86 3/25/86 Two solidified waste liners Two solidified waste liners Dewatered resin (19 tranfix demins)
Dry solids (filters)
in OH 142 HIC Solidified resin Dewatered resins Shipping and supporting waste classification documentation was examined.
With the exception of shipment number 85-SH-037, no concerns were identified.
With respect to shipment number 85-SH-037, the records available contained none of the data supporting the classification.
The shipment, consisting of unsolidified spent filters and dry waste in a high integrity container, was the largest from the standpoint of curie content (67.8 curies) of any made to date.
The licensee's quality assurance staff had identified concerns'ith respect to this shipment (reference Audits and A
raisals section).
In response to these concerns, the licensee's corporate health physics staff was attempting to recreate or duplicate the missing classification documentation from the available data.
This matter is considered unresolved and will be examined during a subsequent
'inspection (50-528/86-13-02).
0,
No violations or deviations were'dentified.
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, open items, deviations or violations.
8.
Review of Xicensee Re orts The inspector reviewed Licensee Event Reports (IER) related to radiation protection and chemistry matters for Unit 1.
The inspector verified that reporting requirements were met, causes identified or under investigation, that. corrective actions appeared appropriate and that LER forms were complete.
For reports identified with an asterisk, a more detailed on site review was conducted.
Docket No. 50-528 9.
<:85-55-LO Inoperable effluent monitor
~"85-61-LO Improper sample lineup
- "85-61-LI Special Report No.85-023, isolated monitor
~85-65-LO Hydrogen/oxygen analyzer-85-72-IO Inadequate monitoring of gaseous waste
<85-77-LO ESF actuation
="85-77-LI ESF actuation-supplementary report
<85-78-LO Inoperable radiation monitor (RV-141)
"-85-78-LI Supplementary report tt
"=85-81-IO
.
PASS inoperable more than seven days
"-85-85-LO Failure to perform surveillance testing-85-93-LO Radiation monitor, incorrect sample lineup 86-05-LO Inadequate monitoring of gaseous waste
- 86-09-LO Failure to isolate waste gas holdup system
-'86-11-IO Inoperable radiation monitor (RV-141)
="86-15-LO Failure to collect iodine sample after reactor trip The licensee's timely Semiannual Radioactive Effluent Release Re ort for the period July 1-December 31, 1985, was examined.
No disczepancies or anomalous data was identified.
No violations or deviations were identified.
Followu on IE Information Notices and Generic Letters IE Information Notice No. 85-92, Surve s of Wastes Before Dis osed from Nuclear Reactor Facilities, was discussed with the Radioactive Materials Control Supervisor.
The licensee implements a waste minimization program including potentially clean and contaminated trash containers, piece by piece waste monitoring, bulk sorted waste monitoring, clean waste shredding and clean waste disposal.
The licensee's program was described in Radwaste Guideline, No. 31, Rev. 4, entitled Dr Active Waste Se re ation and Handlin
.
In addition to clean waste sorting using a hand held G.M. detector and ratemetez, all clean waste bags were to be surveyed, with a PRM-5N/SPA-3, NaI (Tl) detector and ratemeter)
in a low background area on the 140 foot elevation.
Any bag reading greater than background was to be reprocessed prior to shreddin It t
Generic Letter No. 85-08,
CPR 20.408 Termination Re orts-Format, was discussed with licensee's representatives.'he licensee plans to implement the use of Standard NRC Form-439.
No violations or deviations were identified.
F 10.
Tours The Unit 1 containment, auxiliary, radwaste, laundry/decon buildings and the fenced, posted, access controlled area used for packaged radwaste and container storage were toured.
Xt was noted that the containment housekeeping was excellent.
The licensee's use of the 100 foot elevation containment access facility appeared to be effective in minimizing the potential congestion at the 140 foot elevation access control point.
In support of the radwaste reduction program, the licensee uses both contaminated waste and nonradioactive waste containers in the auxiliary building. It was noted and called to the licensee's attention that some of the materials placed in the nonradioactive waste containers (e.g.,
plastic booties, cotton, and rubber, gloves') would appear to have been
.more appropriately discarded in the radioactive waste containers.
The licensee explained and the inspector observed that, trash~ from both types of containers is subjected to a piece by pi~ece survey to determine its ultimate disposition.
3uring the tours, confirmatory'urveys were performed using an ion chamber type survey instrument (NRC-015844, due for calibration May 13, 1986).
No discrepancies in posting or labeling were identified.
" In containment radiologically cool zones were identified to minimize exposure during stand by periods.
The Unit, 2 access control area, hot chemistry laboratory and the 100 foot elevation and PASS pit were toured.
No violations or deviations were identified.
11.
Exit Interview The scope and findings of the inspection were discussed with the individuals denoted in report section 1.
The licensee was informed that no violations or deviations were identified.
The concerns associated with radwaste shipment 85-SH-037 were discussed and were identified as a
matter to be examined during a subsequent inspectio I
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