ML17056B665

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Insp Repts 50-220/92-05 & 50-410/92-05 on 920203-07. Violations Noted.Major Areas Inspected:Mgt Organization, Process Control Plan,Documentation,Procedures,Training,Qa & Implementation of Above Programs
ML17056B665
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 02/10/1992
From: Joseph Furia, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17056B663 List:
References
50-220-92-05, 50-220-92-5, 50-410-92-05, 50-410-92-5, NUDOCS 9202210079
Download: ML17056B665 (16)


See also: IR 05000220/1992005

Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION I

50-220/92-05

50-220

Docket Nos.

50-410

DPR-63

License Nos.

NPF-54

Licensee:

Nia ara

Mohawk Power Cor oration

300 Erie Boulevard West

S racuse

New York

13202

Facility Name:

Nine Mile Point Units

1 and

2

Inspection At:

L comin

New York

Inspection

Conducted:-

Februar

3-7

1992

Inspector:

I

~

~ /

"

J

J. Zuria, Senior Radiation Specialist,

Facilities Radiation Protection Section

(FRPS), Facilities Radiological Safety

and

Safeguards

Branch

(FRSSB), Division of

Radiatio

fety and Safeguards

(DRSS)

date

Approved by:

W. Pasciak,

Chief,

FRPS,

FRSSB,

DRSS

'Z~/c

date

Areas

Ins ected:

Inspection

of

the

radwaste

processing,

radioactive materials transportation

and radiological protection

programs including:

management organization,

Process Control Plan,

documentation,

procedures,

training,

quality

assurance,

and

implementation of the above programs.

Results:

Within

the

areas

inspected,

two

violations

were

identified in the area of access

to High Radiation Areas

(Section

3).

Continued good performances in the radwaste

and transportation

programs

were noted.

9202210075'20211

PDR

  • DOCK 05000220

G

PDR

,

Personnel

Contacted

DETAILS

1.1

Licensee

Personnel

  • W. Allen,

MATS Radiological Assessment

Manager

J. Burton, Manager,

QA Operations,

Unit 1

  • R. Cole,

General Supervisor

Radwaste,

Unit 2

  • A. Curren,

Compliance Engineer

  • C. Gerber,'rogram

Manager,

Radwaste

Storage

  • C. Merritt, Supervisor

Radwaste,

Unit 2

W. Scholtens,

Shipping Coordinator, Unit 2

P. Smalley, Radiation Protection Supervisor,

Unit 1

  • P. Swafford, Radiation Protection Manager, Unit 2
  • W. Thomson,

Radiation Protection Manager, Unit 1

  • J. Torbitt, General Supervisor

Radwaste,

Unit 1

C. Ware, Training Supervisor

1.2

NRC Personnel

  • L. Myers, Acting Resident Inspector

W. Schmidt,

Senior Resident Inspector

  • Denotes

those present at the exit interview on February

7.,

1992.

~Pur ose

3.

The

purpose

of this

safety

inspection

was to review the

licensee's

programs

for the

processing

and

packaging

of

radwaste,

transport of radioactive materials,

and a review of

radiation protection practices

during normal operations.

Radiation Protection

On October

23,

1991, five operations

personnel

entered

the

Unit

2 Northeast

and Northwest

Condenser

Areas

on the

277'levation

of the Turbine Building in order to take corrective

actions to mitigate and terminate

a loss of condenser

vacuum.

This area

was a posted High Radiation Area,

and in accordance

with

plant

Technical Specification 6.12

required

that

personnel

making entry were required to be on a Radiation Work

Permit

(RWP), and that each individual or group of individuals,

entering

have

a

survey

meter,

alarming

dosimeter

or

be

accompanied

by

a Radiation

Protection

Technician

having

a

survey meter.

This entry was

made without being

on an

RWP,

and the five operations personnel did not have the appropriate

radiation

detection

equipment

or

coverage

by

a

Radiation

Protection Technician.

While one operator did have

a survey

instrument, the licensee's

own investigation of the event does

not take credit for its presence,,

as

no evidence

could

be

found to indicate that

a

survey

of the

area

entered

was

performed, or that the results of any survey were communicated

0

to the other members of the group entering the High Radiation

Area.

This is an apparent violation (50-410/92-05-01).

On December

16,

1992, three operations

personnel

entered the

Unit

1 South'Condenser

Moisture Separator

Room

on the

277'levation

of the Turbine Building in order to take corrective

actions to mitigate and terminate

a loss of condenser

vacuum.

This area

was

a posted High Radiat'ion Area,

and in accordance

with

plant

Technical Specification 6.12

required

that

per'sonnel

making entry were required to be on a Radiation Work

Permit

(RWP), and that each individual or group of individuals

entering

have

a

survey

meter,

alarming

dosimeter

or

be

accompanied

by

a Radiation

Protection

Technician

having

a

survey meter;

-This entry was

made without being

on an

RWP,

and the five operations personnel did not have the appropriate

radiation

detection

equipment

or

coverage

by

a

Radiation

Protection

Technician.

This is

an apparent violation (50-

220/92-05-01).

In both

instances,

the

operations

personnel

made

the

High

Radiation

Area

entries

in order

to

keep

the

plant

from

tripping off line due to

a loss of condenser

vacuum.

The

problems in both instances

were a lack of notification to the

Radiation

Protection

Department,,and

a

lack of available

alarming dosimeters to the operators.

Radwaste

and Trans ortation

4.1

Mana ement

and Or anization

Processing of plant water and- preparation of radioactive

wastes for disposal

was the responsibility of each unit's

Radwaste

Section of the Operations

Department.

At Unit

1, the General

Supervisor

Radwaste. position had been

filled by the former Radwaste Assistant Supervisor since

the time of the last inspection.

At Unit 2, the General

Supervisor

Radwaste position had

changed

twice since

the last inspection,

and was also now filled by a former

Radwaste Assistant Supervisor.

Staffing levels at each

unit

appeared

adequate

for the

level

of work.

In

addition,

each unit's radwaste staff included contractor

personnel

hired to process

the

waste

streams

into

an

acceptable

waste

form for disposal.

4.2

Unit 1 Radwaste

Since

the last

inspection,

Unit

1

had

undertaken

to

repair various plant radwaste

systems located in the Old

Radwaste Building, and to decontaminate

general

areas in

this structure

below the 269'levation.

Although not

yet completed,

this program

has significantly improved

the work environment for the radwaste

operators.

Unit

1

processed

floor .drain

water

through

a

waste

evaporator,

with the

bottoms

. solidified in

cement,

processed

'primary

and

condensate

waters

through

the

demineralizer beds,

and collected Dry Active Waste

(DAW)

for bulk shipment to Quadrex.

Spent resins,

both of the

powder

and

bead

types

were

dewatered

in polyethylene

liners,

with

the 'ewatering

process

'and

.the

solidification services for evaporator

bottoms provided

by Chem Nuclear Systems,

Inc.

At

the

time

of, this

inspection,

the

licensee

was

examining

several

options 'o

improving'lant

water

processing

and

waste

minimization,

most

notably

by

evaluating the potential to replace the waste evaporator

with a demineralizer

system,

and replacing the precoat

filters with mechanical

septums

that would require

no

precoat.

4.3

Unit 2 Radwaste

Since

the last

radwaste

inspection,

the

licensee

had

twice. replaced

the General

Supervisor

Radwaste,

with

the position filled at the time of this inspection by a

former

radwaste

operator,

who

had

also

worked

as

a

training instructor for radwaste

personnel.

As at Unit

1, the General Supervisor

.Radwaste reported through the

Operations

Manager'to the Plant Manager.

At the time of this inspection, all wastes

generated

by

the licensee

from its clean-up of plant water

systems

were

solidified in

Portland

Type II cement.

This

included

diatomaceous

earth

from its flatbed filter,

wast'e

evaporator

bottoms,

and all resins.

DAW

was

collected

from throughout the plant and brought to the

radwaste facility where it was compacted into B-25 boxes

for eventual

shipment to a disposal site.

1

At

the

time

of this

inspection,

the

licensee

was

investigating

several

options to improve its radwaste

program.

These

included conducting

a test,

of- the

Chem

Nuclear Systems,

Inc. Advanced Liquid Processing

System

(ALPS), first as

a temporary replacement for the flatbed

filter and waste evaporator utilized in the floor drain

system.

The waste evaporator will be unavailable during

the

upcoming refueling outage

due to maintenance.

If

this test

proves

successful,

then

the

licensee

would

consider making the ALPS a permanent

replacement for the

originally designed floor drain processing

system.

The

licensee

was

also

in the

process

of replacing

the

existing cement solidification system with a Chem Nuclear

Systems,

Inc.

RDS-1000

resin

dewatering

system.

The

system

was

on site

at

the

time of this

inspection,

4 '

awaiting final. engineering analysis and approval prior to

installation

and

system

testing.

Operation

of this

system

should result in a significant reduction in the

amount of radwaste

shipped for disposal by the licensee.

Finally, the licensee

had decided to lay up the existing

extruder/evaporator

system,

which had

been

tested

but

never placed into full time use.

Trans ortation

As described

above preparation of radwaste for shipment

to

waste

processors

or

a

disposal

site

was

the

,responsibility

of

each

unit's

Radwaste

Operations

Section.

Preparation of non-waste radioactive materials

for shipment,

including laundry,

was the responsibility

of

each

units

Radiation

Protection

Department.

Previously,

the responsibility for preparing all waste

manifests and transportation

documents rested with a site

Shipping Coordinator.

This position was abolished late

in 1991,

and the responsibilities

transferred

to each

unit s Radiation

Protection

Operations

Section.

The

former site Shipping Coordinator was assigned to Unit 2,

while staff

at

Unit

1

was

designated

to

receive

appropriate training to provide this support.

Until the

necessary

staffing was in place,

the Unit 2 coordinator

also supported Unit 1.

The licensee continued to prepare shipping documentation

utilizing a self-developed

spreadsheet,

although at the

time

of this

inspection, it

was

in the

process

of

changing over to utilizing the Radman

code

(WMG, Inc.)

As part

of this

inspection,

records

were reviewed.

the

following shipping

Shi ment

1291-113

91-114

1291-114

0192-084

0192-024

0192-105

0192-106

1091-126

1091-174

1191-154

1291-286

0192-141

0292-092

1.02E+01

5.41E+04

7.83E+00

3.02E+03

1.59E+Ol

1.31E+Ol

1.09E+00

2.11E+01

2.42E+01

7.99E+00

2.75E-01

1.16E+00

2.74E+01

194. 1

76. 0

194. 1

14.9

194.1

205.8

170.8

181.7

181.7

181.7

900.0

181.7

181.7

Evap Bottoms

Hardware

Evap Bottoms

Hardware

Evap Bottoms

Resin

Resin

Resin

Resin

Resin

DAW

Resin

Resin

All records

were determined to be complete

and to meet

6

all the appropriate

requirements

of 10 CFR Parts 20,

61

and 71,

and

49

CFR Parts

100-177.

4.5

Interim Radwaste

Stora

e

In 1991, the licensee assigned the former Unit 1 Radwaste

General Supervisor to head

a group to plan for the long-

term storage

of, radwaste at the plant, in anticipation of

the January

1, 1993 shutdown of the three existing burial

sites.

Since that time, the licensee

has

examined

two

principle options, the use of existing Unit 1 and Unit 2

facilities

for

the

-storage

of

wastes,

and

the

construction of an On Site Storage Container

(OSSC)

farm

or pad.

Currently

the

licensee

has

two large

existing

areas

available for radwaste

storage.

For spent

resins

and

other higher activity wastes,

the Stock Storage

Area in

the Unit 1 New Radwaste Building might be made available

with

certain

modifications.

This

facility

was

specifically

designed

to store

55

gallon barrels

of

cement

solidified

radwastes

generated

by

the

Stock

processing

system.

"

Its

use

to

store

both unit's

radwastes

would, however,

probably require

an amendment

to the Unit 1 license to allow Unit 2 wastes to be stored

at Unit 1.

For the storage of containerized

DAW, a large

area

on

the 245'levation

of the

Unit

2

Radwaste

Building, under the radwaste truck loading area,

would be

available.

Its

use

would

probable

also

require

an

amendment,

this to the Unit

2 license

to provide for

storage of Unit 1 waste.

4.6

Given the short time remaining before loss of access

to

the existing disposal'ites,

the licensee

needs

to be

more aggressive

in making its decisions

on which waste

storage

option to

use,

and to perform the

necessary

safety analysis, facilitymodifications, and initiate the

necessary

licensing actions.

~Trainin

Since

the last

radwaste

inspection,

the training of

radwaste operators

has been removed from the Non-Licensed

Operators

training,

and

placed

into

the

technical

training

area,

together

with

the

training

program

management

for

the

health

physics

and

chemistry

technicians.

The training program consists

of both

an

initial and

continuing training

program for both the

radwaste

and health physics personnel, with both types of

training involving in-house

classroom,

vendor supplied

training and on-the-job training.

This training program

meets the requirements for training as set forth in NRC

IE Bulletin 79-19.

4.7

Assurance

of ualit

The licensee's

program for the assurance

of quality in

the radwaste

and transportation

programs involved vendor

audits,

in-plant

audits,

surveillances

and

quality

control, reviews of all radwaste

shipments.

Audits

of.

vendors.

supplying

NRC

approved

shipping

containers

and other radwaste 'services

were conducted by

the

licensee's

corpo'rate

vendor

audit.

group.

Chem

Nuclear

Systems,

Inc.

was

approved

to

remain

on the

approved supplier listing in June,

1989,

based

upon the

results of a Nuclear Utilities Procurement Issues Council

(NUPIC)

audit

conducted

by representatives

from Wolf

Creek

Nuclear

Generating

Station.

This approval

was

valid for three years,

and requires

annual review.

The

most recent

annual

review was

conducted

in September,

1991,

and

recommended

continued

use

based

upon

the

results of a second

NUPIC sponsored

audit,

conducted

by

the Nebraska

Public Power District, in November,

1990,

and

a subsequent

audit follow-up conducted

by Carolina

Electric

6

Gas

Company

in April,

1991.

Similar

documentation exists for General Atomics, which has the

lead contract for the spent fuel pool activities at Unit

1, with the triennial approval based upon a Yankee Atomic

Electric Company audit conducted in 1989.

The licensee

had conducted its annual audit of radwaste

activities

in

November,

1991,

with the

audit

report

(591017-RG/IN),

issued

December

12,

1991.

This audit

included

radwaste

activities,

chemistry,

radiation

protection,

Quality

Assurance

Operations

and

environmental monitoring programs for both units.

This

performance

based audit had no findings or deficiencies

identified,

however several

items for improvement

were

documented.

The licensee

conducted

periodic surveillances

at both

units,

and

documented

their findings in Surveillance

Reports.

The scope

and

number of reports

conducted at

Unit

1

was

exceptional,

and

although

the

number

of

surveillances

at unit

2 was

somewhat

less, it was also

noteworthy.

Quality Control inspection

reports

were

on record for

each radwaste

shipment reviewed.

These document Quality

Control type activities which typically included review

and

inspection

of

disposal

liners,

shipping

casks,

transport vehicles,

radiation protection activities in

support

of

radwaste

shipping,

and

verification

of

paperwork

and documentation.

5.

Exit Interview

The inspector met with the licensee representatives

denoted in

Section

1 at the conclusion of the inspection

on February

7,

1992.

The

inspector

summarized

the

purpose,

scope

and

findings of the inspection.