ML17059B955
| ML17059B955 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/30/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17059B953 | List: |
| References | |
| 50-220-98-04, 50-220-98-4, 50-410-98-04, 50-410-98-4, NUDOCS 9804070124 | |
| Download: ML17059B955 (22) | |
See also: IR 05000220/1998004
Text
U.S. NUCLEAR REGULATORYCOIVIMISSION
REGION I
Docket Nos:
License Nos:
50-220, 50-410
Report Nos:
50-220/98-04, 50-410/98-04
Licensee:
Niagara Mohawk Power Corporation
Facility:
Nine Mile Point, Units
1 and 2
Location:
Scriba, New York
Dates:
March 9-13, 1998
Inspectors:
R. Ragland, Radiation Specialist
J.
Furia, Sr. Radiation Specialist
Approved by:
John R. White, Chief
Radiation Safety Branch
Division of Reactor Safety
9S04070124
9S0330
ADQCK 05000220
8
EXECUTIVESUMIVIARY
Nine IVlile Point Units 1 and 2
50-220/98-04 8( 50-410/98-04
March 9-13, 1998
This NRC inspection report includes reviews of licensee activities in the functional area of
plant support.
The report covers a five-day period of inspection and review by Region-
based specialist inspectors.
PLANT SUPPORT
A generally effective program for the collection, processing
and return to the plant
of liquid wastes, and for the collection, processing, storage and transportation of
radwaste was established.
~
One violation of transportation regulations was identified involving the release of a
vehicle (flat-bed trailer) for unrestricted use, that exceeded the radiation limits
specified in 49 CFR 173.443.
Re ort Details
Nine IVlile Point Units 1 and 2
50-220/98-04 & 50410/98-04
March 9-13, 1998
SUMMARy'FACTIVITIES
Nuclear Regulatory Commission (NRC) Staff Activities
Ins ection Activities
The NRC region-based
inspectors conducted inspection activities during normal hours.
The
results of the inspection activities are contained in the applicable sections of this report.
U dated Final Safet
Anal sis'Re
ort Reviews
While performing the inspections discussed
in this report, the inspectors reviewed the
'applicable portions of the Updated Final Safety Analysis Report (UFSAR) related to the
areas inspected.
The inspectors verified that the UFSAR wording was consistent with the
"'observed plant practices, procedures and/or parameters, with the exception of the
following: (1) Section 12 of the Unit 1 UFSAR contains outdated information on the liquid
and solid radwaste processing program and equipment; and, (2) Section 11 of the Unit 2
UFSAR contains outdated information on the liquid and solid radwaste processing program
and equipment.
As previously noted in NRC Inspection Report 50-220/97-07;50-410/97-
07, the licensee has identified these UFSAR deficiencies, and has a program in place to
revise the UFSAR.
I. PLANT SUPPORT
R'I
Radiological Protection and Chemistry (RP&C) Controls
R1.1
Trans ortation and Radioactive Waste Pro rams
a.
Ins ection Sco
e 86750
The inspectors reviewed the licensee's programs for the processing of liquid and
solid radioactive wastes (radwaste) and the transportation of radioactive materials,
including: the Process Control Programs (PCP), scaling factor data for compliance
with 10 CFR 61.55, shipping records, and system walkdowns in radwaste..
b.
Observations
and Findin s
The Unit 1 processing program for radwaste is contained in the Unit 1 Radwaste
Process Control Program, Rev. 4, dated February 26, 1998. This document
accurately reflects current Unit 1 pro'cessing systems and equipment, and is an
significant improvement over Revision 2 of the PCP which was reviewed during
inspection 50-220/97-07.
Subsequent to the conclusion of that inspection, the
Unit 1 PCP was revised in December 1997 (Rev. 3). A subsequent
revision
(Revision 4) effected transfer of management oversight for the radwaste program
from the Operations Department to the Health Physics Group.
All personnel
previously a part of the Radwaste Operations Section were transferred to the Health
Physics Group.
The inspectors reviewed the licensee's
program for determining difficultto measure
radionuclides in its waste streams,
in accordance with 10 CFR 61.55. The licensee
submits, on an annual basis for pertinent waste streams, plant specific samples to a
vendor laboratory for total isotopic analysis.
The results of these analysis are then
reviewed and incorporated into a licensee maintained computer data base.
The
inspectors noted that the licensee currently has only one proceduralized method for
notifying the unit radwaste supervisor when plant conditions change that may affect
waste stream specific scaling factors of greater than an order of magnitude.
Such
change could potentially invalidate the scaling factors in use in accordance with the
NRC's Low-Level Waste Licensing Branch Technical Position (BTP) on Radioactive
Waste Classification (May 1983). The only licensee method that has the potential
of addressing
interim plant condition changes that affect scaling factors relies on
data collection on a quarterly basis.
Such method may not be completely effective
if radiological conditions changed rapidly.
Due to current plant practice of storing
most radioactive wastes onsite (especially spent resins) for at least one year, the
impact of this current methodology is minimal since the shipments would not likely
be made before the next annual reassessment
of scaling factors.
The inspectors
discussed this issue with both unit Radwaste Managers, who indicated that this
matter would be reviewed further with the unit Chemistry Managers to determine
appropriate corrective action.
The licensee's resolution of this matter willbe
examined in a future inspection. (IFI 50-220/98-04-01)
The inspectors conducted
a detailed system walkdown of the radwaste facilities.
The inspectors conducted direct visual observation in all but three of the radwaste
facilities'ubicles.
Three areas posted as airborne radioactivity areas were not
entered.
All areas reviewed, except as noted below, were determined to be
appropriately posted and generally well maintained from the perspective of
radiological housekeeping.
The exception to this were the areas around the two
waste collector pumps, ¹11 and ¹12, located on the 229'levation.
Both pumps
were observed to be actively leaking at their seals.
A review of records indicated
that a work order to correct this situation was issued, but also that this is the third
time since 1995 that these pumps have leaked at their seals.
Although the leakage
was currently being maintained within the
posted contaminated
area of the pump
base, the inspectors noted that back the late 1980's and early 1990's these pumps
had been observed spraying water from their seals, resulting in extensive
contamination.
At the exit meeting on March 13, 1998, the Unit 1 Plant Manager
indicated that the status of these pumps and their maintenance would be reviewed.
Although this issue indicates poor housekeeping
in this one cubicle, the facility, as
described in the UFSAR, was designed to contain leaks and spills of potentially
contaminated materials.
No violations of NRC requirements was identified.
0
The inspectors reviewed the records of three radioactive materials shipments,
including a shipment of spent resins to a radwaste processor made on March 11,
1998, which was observed by the inspectors.
The shipment records reviewed were
determined to meet the applicable provisions of 10 CFR Parts 20, 61 and 71, and
49 CFR Parts 170-178, for waste classification and form, shipping and radwaste
manifests and transportation communications.
On February 6, 1998, the licensee returned to service from'nit 1, an empty flatbed
trailer. The trailer had arrived onsite previously containing boxes of radioactively
contaminated equipment for use in the spent fuel pool. The empty trailer was sent
to the Babcock and Wilcox (B5W) facility in Parks Township, Pennsylvania.
The
licensee's documentation of the vehicle survey did not identify any contamination or
radiation levels on the trailer in excess of the regulatory limits. Therefore, the trailer
was released for unrestricted use without the need for any additional controls or
postings.
On February 9, 1998,
BtkW conducted
a receipt survey of the trailer and
discovered two accessible
areas on the trailer surface which had contact radiation
levels in excess of Department of Transportation (DOT) limits contained in 49 CFR
173.443, i.e., [0.005 mSv/hr {0.5 mrem/hr)]. The two areas were determined to
, be 0.014 mSv/hr (1,4 mrem/hr) and 0.300 mSv/hr (30 mrem/hr), respectively.
Upon notification by BRW, the licensee dispatched
a radiation protection technician
and supervisor to the BOW location and confirmed the presence of the two
locations with higher than allowable radiation levels.
The licensee temporarily
suspended
all further shipments of radioactive materials or release of vehicles for
unrestricted use.
It resumed these activities later in February 1998 upon
establishing a more comprehensive survey methodology with a group of specially
trained radiation protection technicians.
The return to service of an empty vehicle
that was previously used to ship radioactive materials as an exclusive use vehicle
with radiation levels in excess of DOT limits, is an violation of 10 CFR 71.5. Title
10 CFR 71.5 requires that NRC licensee's comply with all applicable DOT
requirements,
including 49 CFR 173.443. (VIO 50-220/98-04-02)
NMP2
The Unit 2 processing program for radwaste is contained in the Unit 2 Radwaste
Process Control Program, Rev. 3, dated December 18, 1997. This document
accurately reflects current Unit 2 processing systems and equipment, and is an
improvement over Revision 2 of the PCP which was reviewed during inspection
50-410/97-07.
This version of the PCP now accurately includes references to the
Thermex system which is utilized in the unit to process both waste collector and
floor drain inputs.
The inspectors conducted
a detailed system walkdown of the radwaste facilities,
The inspectors conducted direct visual observation in all but one of the radwaste
facilities'ubicles.
An area posted as airborne radioactivity area was not entered.
All areas reviewed, except as noted below, were determined to be appropriately
posted and generally well maintained from the perspective of radiological
housekeeping.
The exception to this were the pipe chase located below the
309'levation
of the radwaste facility, the spent resin tank cubicle and pump room and
the sludge agitator and waste tank cubicle, where resins were observed on the
floor. In the case of the spent resin tank pump and waste tank cubicles, discrete
piles of spent resin were observed.
In the spent resin tank cubicle, the entire floor
surface was covered in resin.
The inspectors discussed their findings on this matter
at the exit meeting on March 13, 1998. At this meeting the Unit 2 Plant Manager
indicated that this condition would be remediated.
The inspector noted that though
this issue indicates poor housekeeping
in this one cubicle, the facility, as described
in the UFSAR, was designed to contain leaks and spills of potentially contaminated
materials.
No violation of NRC regulatory requirements was identified.
The inspectors reviewed the records of four radioactive materials shipments,
all of
which were determined to meet the applicable provisions of 10 CFR Parts 20, 61
and 71, and 49 CFR Parts 170-178, for waste classification and form, shipping and
radwaste manifests and transportation communications.
c.
Conclusions
The licensee has established
a generally effective program for the collection,
processing
and treatment of liquid wastes and the collection, treatment, storage and
shipment of radwaste and radioactive materials.
However, housekeeping
concerns
were identified in both unit's radwaste facilities. Further, one apparent violation of
DOT requirements was identified at Unit 1.
R8
Miscellaneous Plant Support Issues (86750,92904)
R8.1
0 en Violation 1013
EA 97-530: Shi ment of Radioactive Material with
Radiation Levels in Excess of DOT Limits
By letter dated February 23, 1998, Niagara Mohawk Power Corporation submitted
its Reply to Notice of Violation and Proposed Imposition of Civil Penalty.
In this
letter, short-term corrective actions for this violation included Radiation Protection
Manager review of all radioactive material shipments, and long-term corrective
actions included providing radiation protection technicians with continuing training
on the event and revising radiation protection survey procedures.
The inspectors verified that the short-term corrective action is currently in place,
and discussed with both Training Department and Radiation Protection personnel
the status of the long-term corrective actions.
Training personnel indicated that
they were awaiting final corrective actions, including any revised procedures
development, before initiating continuing training. The Radiation Protection
Managers indicated that revised survey procedures would be issued by April 30,
1998, as committed to in the response
letter.
R8.2
Closed
IFI 50-220 97-0-08:Identification of Conditions in Waste Concentrator
Tank ¹11 and Tank Cubicle
By letter dated January 5, 1998, Niagara Mohawk Power Corporation submitted its
Response to Request for a Plan of Action Regarding ¹11 Concentrated Waste Tank.
In this letter, the results of two entries into the tank and pump cubicle were
documented, together with a general action plan for remediation.
As part of this
inspection,
a review of documentation, including a videotape of the entries was
made by the inspectors.
At the exit meeting on March 13, 1998, the Unit 1 Plant
Manager committed to complete the following actions by December 31, 1998
regarding the ¹11 Concentrated Waste Tank, Tank Cubicle and Pump Cubicle:
(1) remove all encrusted concentrates
from the floors and piping in the cubicle;
(2) remove all loose debris, such as hoses, wires and paper trash from the cubicle;
and, (3) remove pieces of asbestos
insulation which have fallen onto the cubicle
floors. The licensee did not commit to removing any of the residual concentrates
from the inside of the ¹11 Waste Concentrates
Tank or to conduct a total asbestos
abatement of the cubicle at this time. Such final decontamination willbe included
in a site decommissioning plan.
R8.3
Closed
Violation 1034
EA 97-530: Im ro er Transfer of Licensed Material
By letter dated February 23, 1998, Niagara Mohawk Power Corporation submitted
its Reply to Notice of Violation and Proposed Imposition of Civil Penalty.
In this
letter, short-term corrective actions for this violation included amending licensee
procedures to require that all transport of radioactive materials from the site be
handled by the appropriate radwaste section, and not by warehouse personnel.
These procedural changes
have been completed.
R8.4
0 en Violation 1033
EA 97-530: Shi ment of Incorrect Liner of Radwaste to a
Processor
By letter dated February 23, 1998, Niagara Mohawk Power Corporation submitted
its Reply to Notice of Violation and Proposed Imposition of Civil Penalty.
In this
letter, short-term corrective actions for this violation included personnel disciplinary
action, meetings with the responsible managers overseeing radioactive waste
shipments and an inventory verification of the liner storage facility. The inspectors
verified that all of the short-term corrective actions have been completed.
The
inspectors noted, however, that no long-term corrective actions were proposed,
such as amending its procedure GAP-RPM-01, Interim Storage of Low-Level
Radioactive Waste, or any other procedure, to include a periodic inventory of the
liner storage area, in order to preclude recurrence.
Discussions with the unit
Radwaste Supervisors indicated that such a procedural change will be evaluated.
R8.5
Closed
EEI 50-220 97-07-13and 50-410 97-07-13:Failure to Verif the QA
Pro ram of Radwaste Processin
Vendors
By letter dated January 22, 1998, the NRC issued
a Notice of Violation and
Proposed Imposition of Civil Penalty (EA 97-530) to the Niagara Mohawk Power
Corporation.
Included in this letter was a discussion which left this item as
unresolved while awaiting final review by the NRC. Subsequent
review by the
NRC's Office of Nuclear Material Safety 5 Safeguards,
Division of Waste
Management,
has determined that such an audit is not required under NRC
regulations'.
Although incorporated as a requirement under the Unit 1
PCP'revision
2), the requirement was not clear as to its application to off-site waste
processing,
and has subsequently
been removed from the current revision of the
PCP.
R8,6
Closed
UNR 50-220 98-01-12: Potentiall
Contaminated Truck Released from
Unit 1
As discussed
in Section R1 of this report, this item is a cited violation. The
unresolved item is therefor administratively closed.
V. IVlana ement Meetln s
X1
Exit Meeting Summary
The exit meeting occurred on March 13,1998.
During this meeting, the
inspectors'indings
were presented.
NMPC did not dispute any of the inspectors'indings
or
conclusions.
Based on the NRC Region
I review of this report, and discussions with NMPC
representatives,
it was determined that this report does not contain safeguards
or
proprietary information.
PARTIALLIST OF PERSONS CONTACTED
Nia ara Mohawk Power Cor oration
R. Abbott
D. Barcomb
D. Bosnic
J. Burton
J, Conway
R. Dean
S. Doty
K. Dahlberg
G. Gresock
M. Gridley
J. Helker
T. Hogan
C. Merritt
B. Murtha
L. Pisano
N. Rademacher
R. Randall
K. Rowe
V. Schuman
R. Smith
A. Taylor
J. Torbitt
M. Wallace
K. Ward
D. Wolniak
Vice President, Nuclear Engineering
Manager, Unit 2 Radiation Protection
Manager, Unit 2 Operations
Manager, Quality Assurance
Vice President, Nuclear Generation
Manager, Unit 2 Engineering
Manager, Unit 1 Maintenance
Plant Manager, Unit 2 (Acting)
Licensing
HRD
WC/OMG Manager, Unit 2
Radiation Protection Supervisor, Unit 1
Chemistry Manager, Unit 2
Operations, Unit 1
Manager, Unit 2 Maintenance
Executive Staff
Mana'ger, Unit 1 Engineering
ALARASupervisor, Unit 2
Manager, Unit 1 Radiation Protection
Plant Manager, Unit 1
Radwaste Supervisor, Unit 2
Radwaste Supervisor, Unit 1
Radiation Protection, Unit 1
Technical Support Manager, Unit 2
Manager, Licensing
INSPECTION PROCEDURES USED
Solid Radwaste Management 5 Transportation of Radioactive Material
Follow Up - Plant Support
ITEMS OPENED, CLOSED, AND UPDATED.
~Oened
50-220/98-04-01
50-220/98-04-02
IFI
Followup on scaling factor determination relative to changing
plant conditions
Empty vehicle transport with radiation levels in excess of DOT
limits [49 CFR 173.443(c)]
Closed
50-220/97-07-08
IFI
Identification of conditions in waste concentrates tank ¹11
EA 97-530¹1034
Improper transfer of licensedmaterial
50-220 8L
50-410/97-07-1 3
Failure to verify the QA program of radwaste processing
vendors
50-220/98-01-12
Potentially Contaminated Truck Released from Unit 1
~Udeted
EA 97-530, ¹1013
Shipment of radioactive material with radiation levels in excess
of DOT limits
EA 97-530¹1033
Shipmentof incorrect liner of radwasteto
a processor
T
LIST OF ACRONYMS USED
CFR
IFI
mrem/hr
mSv/hr
NMP2
Radwaste
Code of Federal Regulations
Escalated Enforcement Item
Inspector Follow-up Item
mllirem per hour
millisieverts per hour
Nine Mile Point Unit 1
Nine Mile Point Unit 2
Quality Assurance
Radioactive Waste
Updated Final Safety Analysis Report
V.