ML17157A319

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Insp Repts 50-387/90-16 & 50-388/90-16 on 900813-17. Violations Noted.Major Areas Inspected:Transportation & Solid Radwaste Programs Including:Mgt Controls,Audits & QA
ML17157A319
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 09/06/1990
From: Bores R, Joseph Furia
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157A317 List:
References
50-387-90-16, 50-388-90-16, NUDOCS 9009240172
Download: ML17157A319 (9)


See also: IR 05000387/1990016

Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

50-387/90-16

tt tt.

~t-

-tt

50-387

Docket No.

50-388

NPF-14

License

No.

NPF-22

Licensee:

Penns

lvania

Power

& Li ht

Com an

2 North Ninth Street

Allentown

Penns lvania

18101

Facility Name:

Sus

uehanna

Steam Electric Station

Units

1

& 2

Inspection At:

Berwick

Penns lvania

Inspection

Conducted:

Au ust 13-17

1990

Inspector:

J.

uria, Radiation Speci,

Eff1

nts

Radiation Protection

Se

'on

(ERPS), Facilities

Radiological

Safety

and Safeguards

Branch

(FRSSB),

Division of Radiation Safety

and Safeguards

(DRSS)

r

g/d/5'o

date

Approved by:

R, Bores,

Chief,

ERPS,

FR

,

DRSS

e/a/po

date

Inspection

Summary:

Ins ection

on Au ust 13-17

1990

Combined

Ins ection

Re ort Nos.

50-387 90-16

50-388 90-16

Areas

Ins ected:

Routine,

unannounced

inspection of the transportation

and

solid radioactive

waste programs'ncluding:

management

controls; audits;

quality assurance;

and implementation of the above

programs.

Results;

Within the areas

inspected,

one violation in radwaste

(scaling

factors)

was identified (See Section

3. 1).

SOOS24OCWZ

SonS Or

PDR

ADOCK 05000387

PDC

1.

Personnel

Contacted

DETAILS

1.1

Licensee

ersonnel

G. Appel, Chemist

J. Fritzen, Radiological

Operations

Supervisor

  • D. Hagan,

Radiation Protection Supervisor

  • F. Jaeger,

Health Physics

Radwaste

Foreman

J.

Lex, Nuclear General

Training Supervisor

  • R. Prego, guality Assurance

Supervisor

- Operations

D. Rarick, guality Control Inspector

H. Riley, Health Physics Supervisor

  • N. Sawicki,

Radwaste

Operations

Engineer

J. Schmidt,

Nuclear guality Assurance Analyst

  • H. Stanley,

Superintendent

of Plant

G. Walker, Health Physics Technician

R. Wehry,

Compliance

Engineer

V. Zukauskas,

Assistant

Health Physics

Radwaste

Foreman

1.2

Commonwealth of Penns lvani

  • D. Ney, Department of Environmental

Resources,

Bureau of Radiation

Protection

1.3

NRC Personnel

  • S. Barber,

Senior Resident

Inspector

  • J. Stair,

Resident

Inspector

  • Denotes

those present

at the exit interview on August 17,

1990.

2.

~Per ose

The purpose of this routine inspection

was to review the licensee's

program for the preparation,

packaging

and transportation of radioactive

materials.

3.

Trans ortation

and

Radwaste

The licensee's

program for the packaging

and transportation

of

radioactive materials,

including solid radwaste,

was conducted jointly

by the Operations

and Health Physics

Departments.

Spent resins

and

filters were processed

and placed in liners by the Operations

Department,

with shipping casks

procured

and shipping documentation

prepared

by the Health Physics

Department.

Dry Active Waste

(DAW) was

collected

and sorted

by contractor personnel

under the direction of the

Health Physics

Department.

Radwaste

The licensee

produced

waste

streams of solid radwaste,

spent

resins,

spent filters and

DAW.

Resins

were typically dewatered

in

High Integrity Container s (HICs) utilizing a dewatering

system

supplied

and operated

by Scientific Ecology Group

(SEG).

SEG also

provided filtration services

which allowed the licensee to bypass

the existing radwaste

evaporator

systems.

DAW was shipped for

segregation

and disposal

to SEG.

In addition, the licensee

had

an

extensive

system for the analysis

and sorting of "clean" trash

removed

from the radiation controlled areas, utilizing a Hydro

Nuclear sorting,

shredding

and monitoring system,

to ensure that

no radioactive materials

were improperly released

from the site.

As part of this inspection,

the following procedures

were

reviewed.

AD-gA-IOO, Rev 7, "Station Organization

and Responsibilities"

AD-gA-311, Rev 9, "Solid Radioactive

Waste

Process

Control

Program"

CH-TP-055,

Rev 1, "Solid Radwaste

10 CFR 61 Correlation Factor

Determination"

HP-TP-800,

Rev 14,,"Shipment of Radioactive

Waste Material"

HP-TP-801,

Rev 9,

"General

Shipment of Radioactive Material"

HP-TP-804,

Rev 10,

"Shipment of Contaminated

Laundry Via Exclusive

Use 'Vehicle"

HP-TP-807,

Rev 5, "Specific Site Criteria for Radwaste

Shipment to

the Chem-Nuclear

Systems,

Inc. Barnwell, South Carolina Disposal

Site"

HP-TP-851,

Rev 10,

"Radwaste

Curie Calculations"

HP-TP-852,

Rev 1,

"Use of the HN-215H Shipping Package"

HP-TP-860,

Rev 5, "Transfer of Radioactive Material to the

Low

Level

Radwaste

Holding Facility (LLRWHF)"

HP-TP-862,

Rev 2,

"LLRWHF Container Inspection"

HP-TP-880,

Rev 0, "Operation

and

Use of the Wastetr ak Code"

OP-068-121,

Rev 3, "Transfer and Dewatering

Bead Resin In Radlock

Containers to Less

Than

1% Free Water"

3.2

All procedures

were found to be complete

and to accurately reflect

existing plant processes,

with the exception of AD-(A-100, which

has not been

updated to reflect major changes

to the Health

Physics

Department organizational

structural.

The licensee

submitted plant samples to SAIC, Inc. for analysis of

isotopic content every

9 to

12 months.

Results of these

analyses

were then entered

into the Wastetrak

computer data

base for

development of waste

stream specific scaling factors.

Beginning

in 1984,

the licensee

began dewatering

some spent resin

streams

instead of the previously utilized solidification process.

However, the licensee

continued to sample the wet waste

stream

and

base their radiochemical

analyses

on

a wet waste

stream,

resulting

in under reporting the activities of most isotopes

in these

radwaste

shipments.

In addition, the licensee

in February

1989

began utilizing a new resin in the Reactor

Water Clean-Up

System.

A, liner containing

a mixture of this new resin

and the previously

utilized resin

was shipped without first analyzing

and developing

a scaling factor for this waste stream.

This is

an apparent

violation of 10 CFR 61.55(a)(8)

which permits the utilization of

scaling factors if they can

be directly correlated

to actual

plant

conditions

(50-387/90-16-01;

50-388/90-16-01).

Although the

licensee

did identify this violation in May, 1990, there

was

available guidance

from both the

NRC and the industry on the

appropriate

development of scaling factors which could have

prevented

the licensee

from improperly quantifying the wastes.

In June,

1990, the licensee

discovered that anaerobic microbial

organisms

were in the liquid radwaste

spent resin

system,

causing

the generation of methane

gas in dewatered

HICs.

At the time of

this inspection,

the licensee

had

suspended

shipments of this type

of spent resin,

and were investigating various methods for

treating this waste

stream to prevent

gas generation.

This item

remains

unresolved

pending licensee

actions

(50-387/90-16-02;

50-

, 388/90-16-02).

Trans ortation

Shipment of radioactive materials

was the responsibility of the

Health Physics

Department.

The Radwaste

Section

prepared all

shipping manifests

through the utilization of the Impell

Corporation's

Wastetrak

computer code.

As part of this inspection,

the following 21 waste

shipment

records

were reviewed.

~Shi ment

90-040

90-043

90-044

Activit

Ci

7.13E-01

2. 76E+01

2.34E-05

Volume

cu ft

195.2

114.9

0.5

~Te

Resin

Filters

Samples

~Shi

ment

~ii ii

Ci

~V1

fi

T~

90-046

90-048

90-051

90-054

90-055

90-056

90-057

90-059

90-060

90-061

90-062

90-063

90-064

90-065

90-066

90-067

90-068

90-071

2.42E-01

2.13E-04

4.18E-02

3.87E-01

1.35E-05

1.35E-05

1.18E+00

2. 71E-01

1.04E-03

1.02E-01

6.01E-02

4.34E-04

1.98E+00

2.91E-01

1.60E-05

1.60E-05

3.06E+00

3.62E-01

195.4

132.0

720.0

177.3

0.5

0.5

1280.0

195.2

0.5

720.0

224.0

0.5

195.2

195.2

0.5

0.5

195.2

2560.0

Resin

RHR Motor

Laundry

Resin

Samples

Samples

DAW

Resin

Samples

Laundry

Equipment

Samples

Resin

Resin

Samples

Samples

Resin

DAW

3.3

3.4

All shipments

were determined to meet the requirements

of 10

CFR

and

49 CFR.

Interim Radwaste

Stora

e

As part of this inspection,

the licensee's

plans for the storage

of radioactive wastes

on site were examined.

Currently the

licensee

has

access

to the three low-level waste disposal

sites

until January,

1993.

The licensee

is located within the

Appalachian

Compact,

which is not scheduled

to have

a disposal

site open until 1996.

In preparation for the loss of offsite

disposal,

the licensee

had constructed

a

Low Level

Radwaste

Holding Facility (LLRWHF), designed to hold up to five years of

plant generated

radwaste.

Based

upon current generation

rates,

the licensee

has

more than sufficient storage

capacity in the

LLRWHF.

The licensee

has

by procedure

HP-TP-860 prohibited the

storage of dewatered

wastes

in the

LLRWHF.

Dewatering of spent

resins is currently utilized extensively

by the licensee.

The

issue of dewatered

spent resin storage

was raised with the

licensee

during the previous inspection of this area in July,

1989.

This item remains

unresolved

awaiting licensee

analysis

and

potential

changes

to the safety analysis report

and procedures

associated

with the

LLRWHF (50-387/90-16-03;

50-388/90-16-03).

ualit

Assurance

1

The licensee's

program for the assurance

of quality in the

radwaste

area involved four sections of the Nuclear guality

Assurance

(NgA) Department.

Staff Auditing was responsible for

conducting periodic audits of the in plant radwaste

program

and of

principle vendors supplying services

and materials

in support of

the radwaste

program.

Procurement guality was tasked with

ensuring that materials

involved in the radwaste

program arriving

at the plant met the terms

and conditions of the various contracts

in place.

guality Surveillance

conducted periodic surveillances

of various radwaste evolutions.

guality Control inspected all

shipments of radioactive material prior to leaving the plant.

As part of this inspection,

the most recent audits of the plant

radwaste

program

and of the principle vendors for this program

listed below were reviewed.

3.5

Audit 89-027,

December

21,

1989, Subject:

Solid Radioactive

Waste

Process

Control

Program

Audit 88-032,

Hay 5,

1988, Subject:

Westinghouse

- Hittman

Nuclear,

Inc.

Audit 88-087,

December

28,

1988, Subject:

Scientific Ecology

Group, Inc.

Audit 88-022,

Hay 18,

1988, Subject:

Chem-Nuclear

Systems,

Inc.

There were

no findings as

a result of these audits.

The scope

and

technical

depth of the audits

was determined to be excellent.

Two surveillances

conducted

in the radwaste

area during 1990 were

examined

as part of this inspection.

guality Assurance

Surveillance

Report

(gASR)90-001

was

a general

review of radwaste

operations

while gASR 90-025 included

a surveillance of the

processing

of contaminated

waste oil by a vendor.

The technical

depth of these surveillances

was determined to be very good.

Overall, the program for the assurance

of quality in the radwaste

area

was determined to be

a notable strength.

~Trainin

The licensee's

training program for radwaste

personnel

continues

to be one of excellent training quality,

and meets

or exceeds

the

requirements

of NRC IE Bulletin 79-19.

At the time of this

inspection,

the licensee

was revising procedure

NTP-(A-42.3,

"Radwaste

Worker Training", to expand

and clarify the listing of

those

personnel

required to take at least

one of the training

modules or approved off-site training courses

offered

by the

Training Department.

With this clarification, the licensee

has

improved the assurance

that all personnel

involved in the radwaste

program receive

appropriate training.

~

~

~

4.

Exit Interview

The inspector

met with the licensee representatives

denoted in Section

1

at the conclusion of the inspection

on August 17,

1990.

The inspector

summarized

the purpose,

scope

and findings of the inspection.