ML17195A838
| ML17195A838 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/17/1985 |
| From: | Haltzman R, Rozak S, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17195A836 | List: |
| References | |
| 50-237-85-21, 50-249-85-17, NUDOCS 8506240105 | |
| Download: ML17195A838 (7) | |
See also: IR 05000237/1985021
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/85021(DRSS); 50-249/85017(DRSS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
P. 0. Box 767
Chicago, IL
60690
Facility Name:
Dresden Nuclear Station
Inspection At:
Dresden Nuclear Station, Units 2 and 3
Inspection Conducted:
May 21-23, 29, and June 5, 1985
S/ 2
Inspectors:
S.
1
Rofat
~/,.#~
Approved By:
M. C. Schumacher, Chief
Independent Measurements and
Environmental Protection Section
Inspection Summary
(:, / 1t-/ ?':J-
Date
Inspection on May 21-23, 29 and June 5, 1985 (Reports No. 50-237/85021(DRSS);
50-245/8S017(DRSS))
Areas Inspected:
Special unannounced inspection of implementation of
10 CFR Part 61 and 10 CFR Part 20.311 requirements for disposal of low-level
radioactive wastes, quality control, tour of the facility, and implementation
of waste form and waste classification requirements.
The inspection involved
45 inspector-hours on site by two NRC inspectors.
Results:
One apparent item of noncompliance was identified (Severity Level V
Supplement IV violation - failure to include quantities of H-3, C-14,Tc-99 and
I-129 on manifests - Section 4) .
8506240105 850617
ADOCK 05000237
G
DETAILS
1.
Persons Contacted
1J. Wujciga, Production Superintendent
18. Stephenson, Manager of Production, CECo
1D. Sharper, Waste Systems Engineer
1 , 2M. Luoma, Quality Assurance Supervisor
1K. Norbert, Nuclear Services Technical, CECO, General Engineer
1L. Oshier, Health Physicist, Radwaste
S. McDonald, Rad-Chem Supervisor
J. Thuot, Staff Assistant, Operations
C. Fullwood, Chem-Nuclear
R. Adams, Intern
1C. Anderson, Resident Inspector
J. Doyle, Quality Control Supervisor
1Present at plant exit interview on May 23, 1985
2Telephone discussions on May 29, 1985 and June 10, 1985
2.
Licensee Action on Previous Inspection Findings
a.
(Closed) Open Item (50-237/85025-02; 50-249/83-23-02): Procedure
DCP 1900-2,
11Quality Control Program for Chemistry Instrumentation,
11
will be reviewed by March 1, 1985 to remove subjectivity in
implementation.
The inspectors examined a reviged version of
DCP-1900-2, approved May 18, 1985.
This procedure was modified to
rephrase the more important quality control measures to make them
mandatory rather than to be recommendations.
The procedures appears
to be adequate.
b.
(Closed) Open Item (50-237/84-25-01; 50-249/84-22-01):
Analyze
waste tank sample for H-3, Sr-89, Sr-90 and gross beta and report
results to Region III.
The results of comparisons made on these
four analyses are presented in Table II.
Comparison criteria are
outlined in Attachment 1.
The disagreement for Sr-89 is probably not
significant.
Analyses of radiostrontium require several steps in
the chemical separations that can introduce errors not reflected in
the acceptance criteria used.
This factor along with the low levels
of Sr-89 involved and no recent history of problems with this type of
analysis does not appear to warrant any extraordinary followup
action.
This matter will be examined further when the next series
of sample comparisons is performed.
3.
Organization and Management Controls
The inspectors reviewed the administration and management of the
licensee's radwaste program.
The radwaste processing is under the
Assistant Superintendent, Operations, and operated by the Waste Systems
Engineer with five Staff Assistants.
The radiological controls and
measurements are performed by Rad-Chem Technicians '(RCTs) under the
2
superv1s1on of the Health Physicist, Radwaste, who is under the Radiation
Protection Supervisor.
Both this group and the Chemistry group, which
provides analyses on the isotopic composition of the samples, are under the
Rad Chem Supervisor.
The cooperation among the three groups involved appears adequate and no
problems were identified.
4.
Waste Classification and Form
The inspectors reviewed the status of the licensee's implementation of
the requirements of 10 CFR 20.311 and 10 CFR 61 applicable to low-level
radwaste classification, waste form and stabilization.
The licensee has made
several hundred shipments to date since December 27, 1983, the effective date
of the new regulations.
The inspectors examined selected manifests and
records of more than 100 shipments covering the period from January 16, 1984
through May 21, 1985.
The licensee's program for waste classification, waste stabilization, and
manifest preparation and tracking is contained in several documents.
The
governing document is procedure DOP 2000-44, "Radwaste Shipping." This
procedure addresses the applicable requirements in 10 CFR 20.311 and
10 CFR 61 for making radwaste shipments to burial -grounds.
It is
implemented under the cognizance of the Waste Systems Engineer.
Other
procedures exist to assist in performing detailed measurements and
calculations.
As an example, procedure DRP 1520-1, "Determination of
Waste Classification for Radioactive Waste Burial" gives a detailed
guidance for determining waste classification.
In practice these
calculations are performed by computer programs generated in-house.
This
program is being used on an interim basis pending company approval of a
comprehensive co~puter code titled WASTETRAK, which is expected to be
approved in the very near future and will replace the existing program.
The licensee generates three types of waste, primarily: dry active waste
(DAW) shipped in 55 gallon drums or in LSA boxes, evaporator bottoms, and
spent resin.
The latter two are solidified either in 55 gallon drums or
in cask liners.
The solidification processes are a Stock Equipment Company
process for solidification in 55 gallon drums and a Chem-Nuclear Company
process for cask liners which has been in routine use at the site for the
last two months.
Both processes have undergone testing to demonstrate
that the final product can meet stability requirements.
The licensee has sent samples of radwaste to Science Applications, Inc.
for determination of correlation factors for the "hard to measure"
nuclides used in waste classification.
The first set was sent late in
1983, and the correlation factors were determined and documented in a
report dated January 10, 1984.
A second set has since been collected and
sent for analysis.
In practice, the "hard-to-measure" radionuclides are
correlated to either Co-60 or Cs-137 .
3
~------
To determine waste classification, dose rate measurements are made on the
radwaste container; dose to curie conversion factors are then used to
determine the total radioactivity content of the container; and this
activity is then partitioned into contributions from various radionuclides
based on gamma analyses of representative samples and the correlation
factors determined previously by the contractor laboratory.
The inspectors
checked several calculations used in the waste classification for accuracy
and identified no problems with the calculations.
During the review of the manifests no problems were found with shipments
made during 1984, except for two shipments made on June 6 and June 8, 1984.
For those two shipments, the values for Cs-137 and Sr-90, which may be
critical for the classification, were missing.
The discrepancy was
identified at Barnwell and the licensee was notified.
The licensee then
found that Cs-137 data were missed (the Sr-90 value is correlated to that
of the Cs-137) due to a deficiency in the gamma-ray spectrometry software
(AAIS) that did not add these data to the "Peaks Summary" section of the
report.
A recalculation showed the initial classification to have been
correct.
The manifests were not revised and no written records relating
to this problem were available.
During this inspection, based on inspector
comments, the licensee initiated a written log of communications with the
burial grounds to document problems of this nature.
The AAIS software
has since been revised to reduce the likelihood of a recurrence of this
problem.
Another problem noted with the above mentioned shipments and with the
majority of shipments made during 1985, was that the quantities of Tc-99,
I-129 and less frequently of H-3 and C-14, were not being reported on the
manifests.
Instead the abbreviation N.P. (not present) was entered on
the manifests.
This appears to be contrary to the requirements in
10 CFR 20.311(b) which states, in part, that the total quantity of the
radionuclides H-3, C-14, Tc-99 and I-129 must be shown.
This* is an
apparent item of noncompliance.
For the 1985 shipments, the licensee did
not list the quantities of those radionuclides because of a memorandum from
the corporate office, dated January 31, 1985, which gave instructions not
to list the quantities of these radionuclides whenever they contributed.
less than one percent of the activity in the container.
The inspectors
discussed this matter with a representative of Technical Services, Nuclear,
but no clear basis for this instruction was identified.
One apparent item of noncompliance was identified.
5.
Facility Tour and Quality Control
The inspectors toured the licensee 1s radwaste facility on May 21, 1985.
No problems were identified during the tour.
The inspectors examined licensee audits of the radwaste program performed
since the effective date of the new regulations (December 27, 1983).
These audits did not address the specific requirements of 10 CFR 61.55 and
4
10 CFR 61.56, although one question in audit QAA 12-84-21 did address the
labelling of radwaste containers required by 10 CFR 61.57.
To
demonstrate compliance with 10 CFR 21.31l(d)(3), which requires a QC
program to assure compliance with 10 CFR 61.55 and 61.56, the licensee
forwarded to Region III an audit checklist, approved May 21, 1985, which
was unavailable for review during the onsite portion of the inspection.
This checklist, which was to be used during a scheduled audit in late
May 1985, does address specific questions to 10 CFR 61.55 and
10 CFR 61.56 and appears to be adequate.
No apparent items of noncompliance were identified.
6.
Exit Interview
The inspectors reviewed the scope and findings of the inspection with
licensee representatives (Section 1) at the conclusion of the onsite
portion of the inspection on May 23, 1985 and on June 10, 1985 after
review of additional documentation supplied by the licensee.
The inspectors discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspectors during the inspection.
Licensee representatives did not
identify any such documents/processes as proprietary.
Attachments
1.
Table II, Confirmatory Measurements
Program, Fourth Quarter of 1984.
2.
Attachment, Criteria for Comparing
Analytical Measurements
5
TABLE II
U S NUCLEAR PEGULA TOF~Y COMM I s:;:: I ON
OFFICE OF INSPECTION AND ENFOPCEMENT
CONFIRMATORY MEASUPEMENTS PPOGRAM
FACILITY: DRESDEN
FOR THE 4 QUARTER OF 1984
NRC-------
LICENSEE----
F:E::=:UL T
ERROR
I SOTOPE RESULT
ERROR
L 1,.,1A~:TE
1.
- 3F:-89
7 *-**
- =:F:-'?O
1.
BETA
2.
T TEST RE:=:UL T:=::
A= AGF<:EEMENT
D= DI SAGF::EEMENT
- =CRITERIA RELAXED
N=
-:OMF'AR I :=:ON
.-, OE-05
..::..
8. OE-0'?
3E-0'?
4. BE-0'?
9. OE-08
1. 3E-03
0. OE-01
.(.1. 2E-08 o. OE-01
<7. OE-09 o. OE-01
.-, lE-06
0. OE-01
..::.
---LICENSEE:NRC----
RATIO
T
9.?E-01
6. 7E 01
A
3.6E-01
4. lE 00
[I
r= 4E 00
~, ?E-01
N
. _1,
..:.. .
8 . ?E-01
2. 6E 01
A
ATTACHMENT 1
CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS
This attachment provides criteria for comparing results of capability tests
and verification measurements.
The criteria are based on an empirical
relationship which combines prior experience and the accuracy needs o~*khis
program.
In these criteria, the judgment limits are variable in relation to the com-
parison of the NRC's value to its associated one sigma uncertainty.
As that
ratio, referred to in this program as "Resolution", increases, the acceptability
of a licensee's measurement should be more selective.
Conversely, poorer
agreement should be considered acceptable as the resolution decreases.
The
values in the ratio criteria may be rounded to*fewer significant figures to
maintain statistical consistency with the number of significant figures reported
by the NRC Reference Laboratory, unless such rounding will result in a narro\\ved
category of acceptance.
RESOLUTION
RATIO = LICENSEE VAL UE/~~RC REFERENCE VALUE
Aqreement
<3
No CoiTlparison
23 and
<4
0.4
2.5
>4
and
<8
0.5
2.0
-
>8
and
<16
0.6
1. 67
>16 and
<51
0.75 -
1.33
>51 and
<200
0.80 -
1. 25
>200
0.85
1.18
Some discrepancies may result from the use of different equipment, techniques,
and for some specific nuclides. These may be factored into the acceptance
criteria and identified on the data sheet.