ML17249A862
| ML17249A862 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/01/1980 |
| From: | Crocker H, Markowski R, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17249A858 | List: |
| References | |
| 50-244-79-18, NUDOCS 8004300244 | |
| Download: ML17249A862 (34) | |
See also: IR 05000244/1979018
Text
SOO4300 ++
eport
No
50"244/79-18
Docket No.
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
License No.
Priority
Licensee
Rochest r Gas
and Electric Company
89 East Avenue
Category
Rochester,
14649
R.
E. Ginna Nuclear Power Plant
Facility Name:
Ontario,
Inspection at:
Inspection conducted:
December
3 6
1979
Inspectors:
R.
S.
alar onski,
Renege
Inspector
i- 9
date signed
Approved by.
G. P.
u as,
Radiation Specialist
hJ
H.
W. Crocker,
ting .Chief
Radiation Support Section
date signed
-date signed
8
dat
si gned
Ins ection
Summar
Ins ection on December 3-6,
1979
Re ort No. 50-244/79-18)
P
'
'"0 '"
P
9'
b
inspectors of the licensee's
response
"Packaging
of Low-Level Radioactive
Waste for Transport
and Burial".
Areas inspected
included: regulatory requirements,
burial site requirements,
procedures,
training audits,
inspection of packages
and review of records.
In
addition, the inspector
reviewed actions
taken by the licensee
in response
to previous inspection findings and to the indications of a primary to
secondary
steam generation
leak that occurred
on December
1, 1979.
Region I Form 12
(Rev. April 77)
Upon arrival at 4:15 p.m.,
December 3,
1979 areas of the plant including;
the reactor containment building, auxiliary building, control
room and
outside radioactive material
storage
areas
were toured by the inspectors.
The inspection. involved 66 inspector-hours
on site by two NRC regional
based
inspectors.
Results:
Of the ten areas
inspected.
no items of noncompliance
were
ident>fied in six areas;
two apparent
items of noncompliance
were identified
in one area (Infraction - failure to comply with 10 CFR 71.3 when delivering
licensed material to a carrier for transport,
Infraction - failure to
comply with 10 CFR 71.5,
Paragraph ll); and one apparent
item of noncompliance
was identified in each of the following areas;
(Inspection - failure to
have written procedures
10 CFR 71 Appendix E, Criteria 5, Paragraph
7;
Infraction - failure to respond
to audit findings,
Criteria 16, Paragraph
9; Infraction - failure to comply with a requirement
of the Security Plan,
Paragraph
13).
ry
Persons
Contacted
DETAILS
- C. Anderson,
Manager guality Assurance
J.
Brown, Shift Foreman
- M. Dillion, Security
D. Filkins, Supervisor,
Chemistry
and Health Physics
- E. Gordon, Health Physicist
R. Morrill. Training Coor dinator
B. guinn, Health Physicist
"T. Schuler, guality Control Engineer
S. Spector,
Maintenance
Engineer
- B. Snow, Plant Superintendent
- R. Mood, Security
The inspector also talked with several
other licensee
employees
including members of the health physics,
operations
and maintenance
staffs.
- denotes
those present at the exit interview on December 6, 1979.
Licensee Action on Previous
Ins ection Findin s
(Closed)
Noncompliance .(50-244/76-18-01)
Failure to comply with
back shift requirements for radiation protection coverage.
The
licensee
has assigned
health physics technicians
to each shift to
insure around-the-clock radiation protection coverage.
(Closed) Previously Identified Item (50-244/79-13-01
)
gual ifications
of the Supervisor,
Chemistry and Health Physics.
From interviews
with the individual the inspector determined that his qualifications
(Bachelor of Science
(Chemistry), University courses
in health
physics,
eleven
and one half years of nuclear
power plant experience,
five of which involved applied radiation protection)
meet the
requirement of Technical Specification 6.3.
Review of Licensee's
Res onse to IE Bulletin 79-19
The inspector reviewed Rochester
Gas
and Electri'c Cqrpovation's
response
dated
September
25,
1979 to assure
that all information
required by the bulletin was included and to ascertain
that corrective
action comnitments were made.
Or anization
Procedure
A-201, "Ginna Station Administrative and Engineering
Staff Responsibilities",
Revision-l, dated July 18,
1979 places
responsibility for the control of solid, liquid and gaseous
radioactive
wastes with the Supervisor,
Chemistry
and Health Physics.
The procedure
places responsibility to prepare
procedures for
handling and shipping solid radioactive waste with the Health
Physicist.
He is also assigned
responsibility to oversee
these
operations.
The Operations
Engineer is responsible for directing operations
involving radioactive waste.
No mention of radwaste responsibilities
is made in regard to the
Maintenance
Engineer.
Maintenance
personnel
routinely construct
shipping containers for low specific activity material.
They also
are responsible for preparation of 17H drums used for solidification.
Maintenance
personnel
stated that these actions are performed'under
the direction of the health physics staff.
The i"nspector noted that processing
and shipment of radioactive
waste is a collateral responsibility of each of the professionals
noted above.
Re ulator
Documents
The inspector verified that the licensee
has
a current set of DOT
and
NRC regulations.
The licensee
subscribes
to a commercial
service that provides bi-weekly updates of regulatory changes
and
related matters.
The inspector
noted that no formal procedure
has
been
implemented
to assure that these notifications of regulatory
changes
are implemented
as appropriate
into facility procedures.
Burial Site
Re uirements
At this time the licensee
ships radioactive waste only to the'outh
Carolina burial site.
The inspector
reviewed the licensee's
copy
of Chem-Nuclear
Systems,
Inc. South Carolina Radioactive Material
License
No. 097, 'Amendment
No.
26 dated October 30,
1979.
This is
the most recent revision of that license.
/y
The licensee
also maintains
a copy of the "Barnwell Site Disposal
Criteria" issued
September
28,. 1979 and effective December 1, 1979.
7.
Procedures
In response
to IE Bulletin 79-19, the licensee
stated that approved
procedures
for waste process
operations
and shipment of radioactive
material
had
been established.
inspector reviewed the following procedures:
r
RD-9, Preparing
Waste for Shipment
or Storage,
Revision 4,
dated February
10,
1979
RD-10, Shipping Radioactive Material, Revision 7, dated
February
28,
1979
RD-11, Receipt of Radioactive Materials, Revision 1, dated
July 9,
1979
S-4.1,
Drumming Waste Evaporator Bottoms, Revision 9, dated
November 19,
1979
S-4.4,
Spent Resin
Removal
to Shipping Casks,
Revision 19,
dated October ll, 1979
S-4..4.1,
Spent Resin
Package - Site Receipt and Shipment,
Revision 5, dated
February
10,
1979
S-4.6,
Operation of the Radioactive
Waste Press,
Revision 2,
dated October 29,
1976
M-18.1,
Drum Preparation for Waste Evaporator Bottoms,
Revision
0, dated February 20.
1976
gCIP-21, Shipping
Package
ATCOR LL-50-100 Inspection,
Revision
2, dated
December '4,
1979
gCIP-22, Shipping Package
HN-100 Series
1 Inspection,
Revision
1, dated April 1979
gCIP-23, Shipping Package
6144 Inspection,
Revision 0, dated
May 29,
1979
Based on=this review the inspector
concluded that procedures
RD9 and R010 were in need of revision in order to eliminate
confusion
and inconsistencies
with the "Barnwell Site Disposal
Criteria".
The Health Physicist presented
documents
indicating
these
two procedures
are currently in the process of revision
and upgrade.
Procedures
RD9 and
RD10 will be reviewed in a subsequent
inspection
(50-244/79-18-01).
10 CFR 71 Appendix E, Criterion 5, "Instructions,
Procedures
and Drawings" states
that:
"Activities affecting quality
shall
be prescribed
by documented instructions,
procedures,
or
drawings of a type appropriate
to the circumstances
and shall
be accomplished
in accordance with these instructions,
procedures,
or drawings.
These shall include appropriate quantitative or
qualitative acceptance
criteria for determining that important
activities have been satisfactorily accomplished."
The licensee routinely uses
three different NRC certified
shipping containers
(Certificate of Compliance
(C of C$ Nqs.
6144,
6601, 9086}.
Procedures
S-4.4.1 state that shipping
casks
be prepared
in accordance with the suppliers
instructions.
Based
on a review of documentation maintained
and discussions
with licensee
representatives,
no written procedures
were
provided by the cask supplier or developed .by the licensee
that directed the loading or closure of these
packages
when
utilized on February
1, 1979,
(C of
C 6601) and'ay
29,
1979
(C of C 6144} to ship 86 Ci and 19.88 Ci of licensed radioactive
material
to the waste burial site.
Failure to utilize written procedures
for activities affecting
quality such
as loading and closure of a shipping package
represents
noncompliance with 10 CFR jl Appendix E, Criteria
5
(50-244/79-18-02}.
The inspector
reviewed documentation
generated
pursuant to
procedure
gCIP-21 for the February 1, 1979,
and gCIP-31 for
the May 29,
1979 shipment of radioactive materials.
These
guality Control Inspection
Procedures
appear
adequate
to
assure
that most of the requirements
expressed in'0 CFR 71.54
"Routine determinations"
have been met, however,'either of
these
procedures verify that the package
has
been
loaded
and
closed in accordance
with written procedures.
Procedures
gCIP-21
and gCIP-22 will be reviewed in a subsequent
inspection (50-244/79-18-03) .
8.
~Trainin
References:
A-101, Ginna guality Assurance
Program Implementation,
Revision
0;
A-102.6;
R.
E. Ginna Systems
Familiarization Program;
Revision
0;
A-102.7,
R.
E. Ginna Auxiliary Operator gualification Program,
Revision 0;
A-102.9, Maintenance Training Program,
Revision 0;
A-102.10, Health Physics Technician Training and Responsibility
Limits, Revision 1; and
A-1002, gualification of Surveillance
and Inspection Personnel,
Revision
1
The inspector
reviewed procedure
A-101 to establish
those onsite
organizations
which participate in the transfer,
packaging
and
shipping of low level radioactive material.
It was noted that
operations,
health physics, quality control
and maintenance
personnel
are involved in this activity.
The above procedures
as well as lesson plans, lecture outlines,
and/or examinations
were reviewed
on a sampling basis
to assure
that the training program was designed
to provide sufficient familiarity
with the appropriate
operating procedures,
and methods
were specified
to assure that personnel
have
a sufficient degree of familiarity
with operating
procedures
to assure
safe operations.
The findings in this area
were:
a.
The response
to items
5 and
6 of IE Bulletin 79-1'9 dated
September
25,
1979 stated that training in the operating
procedures
would be completed
by January
1, 1980.
A
During the review of Audit No. 79-33:CA, the inspector noted
that a finding of the audit
(AFCAR 1} indicated that maintenance
department
personnel
did not have procedures
and
had, not
received training to date (i.e. October 5,
1979) in the preparation
of drums and boxes
as required
by 49 CFR 178.
During the sampling review of the lesson
plans associated
with
radioactive waste
systems
and training conducted
by the Health
Physicist in NRC Part
71
and
DOT regulations,
the inspector
noted that preparation of drums and boxes
was not specifically
itemized as
a lecture topic.
During the review of procedures
detailed in Paragraph
7, it
was identified that procedural
coverage
associated
with the
assemblage
of licensed
casks
had not been developed,
and
therefore
had not been incorporated into the training outlines
reviewed
by the inspector.
The inspector discussed
the incorporation of training in
and
NRC shipping regulations into the operator
and systems
training program by January
1,
1980 as stated in the response
with the Training Co-ordinator.
He stated that the incorporation
would occur as scheduled.
Item 4 of IE Bulletin 79-19 stated
the licensee is expected
to
provide procedures
which provide special attention. to controls
associated
with the chemical
and physical
form of the low
level radioactive material.
Item 6 stated that training is
expected
to be provided for processing
waste into an acceptable
chemical
and physical
form.
Item 4 of the response
to this bulletin indicated that a
process
control
system is being developed coincident with the
impending Environmental
Technical Specifications
which will
further define controls for physical
and chemical
packaging.
Review of training provided to those individuals responsible
for the radioactive waste shipping program indicated the
following:
The Supervisor,
Chemistry and Health Physics
and the
Health Physicist attended
a two day seminar
on transportation
of radioactive materials in August 1978
The Health Physicist attended
a training session
on
shipment of radioactive material at the American Nuclear
Society Meeting in November 1979.
He also participated
in a meeting of the American Industrial
Forum's
Sub-
Coomittee on Reactor
Waste Solidification in Washington,
O.C. on November 1,
1979
Assessment
of these training programs
provided by a licensee
representative
indicated, that although,
they were informative,
they did not provide detailed specific guidance frequently
necessary
to permit compliance with federal regulations.
Training of individuals involved in processing
and shipment of
radioactive materials will be reviewed in a subsequent
inspection
(50-244/79-18-04).
9.
~ACh
P
References
guality Assurance
Manual - Ginna Station; various sections;
gA 1801
GS, gualification of Auditing Personnel,
Revision 6;
gA 1802 GS, Audit Scheduling
and Planning;
Revision 7;
gA 1804
GS, Reporting and Followup of RG8E Audit Findings,
Revision 6; and,
A1801, Ginna Station
Response
to Internal Audits, Revision
0
The above references
were reviewed to verify that
an audit program
had been established of all activities associated
with the transfer,
packaging
and transport of low level radioactive wastes.
The above
procedures
provide general
provisions for: qualification of audit
personnel;
a system for assuring that corrective actions are taken
on audit findings; audit scheduling;
and formal audit reports
and
their distribution to management.
10
The inspector further reviewed internal audits report nos.
79-25:GS
and 79-33:CA'dated
September
10,
1979 and October 11, 1979'espectively.
The audits were reviewed to:
assess
the scope of the audit program
related to radioactive waste shipments;
and, verify that corrective
action was administrated
in accordance
with established
procedures.
The findings in this area
were as detailed in the following subparagraphs:
a 0
b.
c
d.
Audits were conducted
as stated in item 8 of the response
to
IE Bulletin 79-'19 dated
September
25, 1979.
The scope of the above referenced
audits included
a review of
the maintenance of regulations;
organizational
and procedural
coverage;
training; and, shipping records.
During the conduct of the audit associated
with report no. 79-
33:CA, the auditor had identified that training and procedures
had not been developed
in the preparation of drums
and boxes
for shipping
as required by 49
CFR 178.
The finding had been formally documented
(AFCAR 1) and transmitted
to the site organization responsible.
AFCAR
1 specified
a due
date of November 12.
1979.
Administrative procedure,
A1801 requires
the submittal of the
response
to an audit finding on or before the due date.
As of
December
5, 1979,
a response
had not been submitted.
This is
contrary to 10 CFR 71, Appendix E, Criterion 16 and procedure
A1801
and is an item of noncompliance
(50-244/79-18-05).
The inspector discussed
the training provided to auditors with
the guality Assurance
Manager.
It was noted that no specialized
training had been provided in low level radioactive waste
shipping.
The equality Assurance
Manager stated that during
previous aduits,
an outside specialist
had been utilized.
The
inspector discussed
the advisability of providing some specialized
training to the appropriate
RG8E personnel
who perform internal
audits,
inspections
and/or surveillances
in this area with the
guality Assurance
Manager.
10.
Onsi te Observation
During the inspection,
a 55 gallon
17H drum containing waste evaporator
bottoms solidified in accordance
with procedure
S-4.1
was selected
for- examination of potential free standing water.
The.lid plug was removed
and the drum inverted over
a drip pan
assembly.
The drum remained in this position for two hours.
The
inspector did not observe
any visibl.e water from this drum.
11.
Records of Shi ments
The inspector reviewed records of shipments of radioactive materials
made in the period from March 1978 to December
1979.
The findings
of'his review are noted below:
a..
The Semiannual
Effluent Release
Report submitted in accordance
with Technical Specification 6.9.3.b
and referenced
in Item 9
of the response
to IE Bulletin 79-19 for the period January
thru May. 1979 was found to have
an inconsistancy.
The first
page states,
"The solid waste shipped included 219.23 curies
of activity in 64,152 cu. ft.
The tabulation of shipments of
solid waste attached
to the report indicates
a total curie
content of 136.76 and total volume of 6,415.2 cu..ft.
The-
inspector audited the- 1979 solid waste shipping records'and
found the total activity to be 136.76 curies
and 6,415 cu. ft.
This matter was brought to the attention of the Superyisor,
Chemistry and Health Physics.
The Supervisor,
Chemistry and Health Physics stated
the matter
will be resolved
and
a correction submitted
as appropriate.
The correction will receiVe
NRC:RI in office reyjeW L50-
244/79-18-06).
b.
10 CFR 71..3 requires that no licensee deliver licensed rater ial
to a carrier for transport except
as authorized jn a genepal
or specific license issued
by the Commission
op as exempted.
A general
license js issued to ship licensed qaterial
pursuant
to 10 CFR 71..12(b) in a package for which a Certificate of
Compliance
has
been issued
provided that the shlppep
has
a
copy of the Certificate of Compliance, all documents
referred
to in that Certificate and compli'es with the terms
and condjtions
of that Certificate.
12
(1)
The inspector reviewed the Certificate of Compliance
No.
6601, Revision
3 and
5 for the Model
No. LL-50-100 cask.
Both revisions of this Certificate of Compliance reference
Drawing No. 1042-B-0004
Rev.
C.
Records of solid radioactive
waste shipments
indicate
262 Ci and
86 Ci of licensed
material
were delivered to a carrier for transport in
this cask on June
26,
1978 and February
1, 1979.
Inspection
of documents
maintained
by the licensee did not include
Drawing No. 1042-B-0004
Rev.
C.
A licensee
representative
acknowledged that they did not have
a copy of this drawing.
A facsimile of Drawing No. 1042-B-0004
Rev.
C was received
by the licensee
on December
5, 1979.
(2)
The inspector reviewed the Certificate of Compliance
No.
6144 Revision
3 for the Model CNSI-6144 cask.
Referred
to in this Certificate of Compliance is a document titled,
"Chem-Nuclear Systems,
Inc. supplement
dated
November 1,
1977.
Records of solid radioactive waste shipments
indicate that 19.88 Ci of licensed material
were delivered
to a carrier for transport in this cask
on May 29, 1979.
Inspection of documents
maintained
by the licensee
did
not reveal
the "Chem-Nuclear Systems,
Inc. supplement
dated
November 1, 1977."
A licensee
representative
acknowledged that they did not have
a copy of this document.
Failure to have
a copy of all documents
referred to in a
Certificate of Compliance for a package
as required by 10 CFR 71.12(b) represents
noncompliance with 10 CFR 71.3 (50-244/79-
18-07).
10 CFR 71.5 requires that
no licensee deliver licensed material
for transport unless
the licensee
complies with the applicable
requirements of the regulations appropriate
to the mode of
transportation
as they relate to marking and labeling of
packages.
49
CFR 172, Subpart
C - "Shipping Papers"
states
in
section
172.203 that, for:
"(d) Radioactive material
(1) the
description for a shipment of radioactive material
must include
the following additional entries
as appropriate:
(i}
The
name of each radionuclide in the radioactive material
that is listed ig
9 173.390 of this subchapter.
Abbre-
viations, e.g.
""9Mo" are authorized..."
13
~ The inspector reviewed the licensee's
Radioactive Materials
Shipment Record
No. 79-2 and the Chem-Nuclear
Systems,
Inc.,
Radioactive
Shipment Record
Form No.
2955 for the February 1,
1979 shipment of Type 8 quantities radioactive materials
to
the Barnwell, South Carolina burial site.
These
forms listed
the below radionuclides
to be present in the radioactive
material.
Nucl ide
134
Cs
137
Cs
"Co
guantity
11,140 millicuries
58,740 millicuries
16,060 millicuries
Total of
86,000 millicuries
This shipment consisted of dewatered
spent resins in a
NRC
certified cask.
Spent resins are likely to contain many
radionuclides typically present at a nuclear facility.
One
radionuclide expected in spent resins is Strontium 90.
A
licensee representative
calculated
an. estimate of 90 Sr. present
in the resins.
This documented
estimate indicates that 58
millicuries of 90 Sr were present.
The licensee
added this
value to the
sum of other radionuclides
known to be present
and documented
a total content of 86,000 millcuries on both
shipping forms.
Review of the June
26,
1978 shipment of spent resins
also
indicate that 30 millicuries of 90 Sr were calculated
to be
present,
but were not indicated on the shipping forms.
Failure to list Type
B quantities of 90 Sr on the shipping
papers
as required in 49
CFR 172.203(d)
represents
noncompliance
with 10 CFR 71.5 (50-244/79-18-08).
"Procedures for picking up receiving,
and
opening packages."
requires that each licensee
who expects
to
receive
a package
containing quantities'of radioactive material
in excess of Type A quantities
must comply with several
requirements
involving timely receipt,
survey and notification of deficiencies.
The licensee
has established
and implemented
procedure
RDll to
insure these requirements
are met.
14
Review of records
indicates that the licensee
received
one
shipment on March 9,
1979 of a Type
B quantity of radioactive
material.
The package
was received
and surveyed in accordance
with procedure RDll.
No notifications were required
based
on
survey results since all applicable requirements
were complied
with.
12.
Tube Leak in "B" Steam Generator
LER-79-022)
On December
1, 1979, at approximately 9:00 p.m., the onshift licensed
operators
noted an increase
in the Air Ejector Radiation Monitor
(R-15}.
Subsequent
followup. action resulted in confirming that a
leak of 0.007 gallons/minute
had developed in the "B" Steam Generator.
A plant shutdown was
commenced at 9:05 a.m.
on December
2, 1979 to
effect repairs.
During this inspection,
the inspectors
reviewed the actions
taken
subsequent
to the identification of the leak.
This review consisted
of discussion with the personnel
onshift at the time and plant
supervision;
and, review of the Official Record, Shift Foreman's
Log, Procedure
0-6. 10, Revision
2
(PCN 79-2583)
and records of
radioanalysis of the Steam Generator.
The inspector determined that:
notification to licensee
management
and the
NRC had been
made;
the procedures utilized to operate
the plant subsequent
to the
identification of the leak were compatible with the calculated
leak rate;
sufficient sampling
was conducted
to assess
the magnitude of
the leak and the offsite releases;
and,
preliminary calculations
performed by the inspector indicated
that the release
to the environment was less
than
11 of the
values specified
by the Technical Specifications
in section
3.92.
No items of noncompliance
were identified.
P
15
13.
Plant Tour
The inspectors
conducted
a general
plant tour.
The areas
toured consisted of the external
areas
inside the security
fence,
the Auxiliary Building, the Containmerit Vessel
and the
Control
Room.
I
During the conduct of this tour the inspectors
observed/
determined:
general
housekeeping
and cleanliness;
temporary storage of low level radioactive waste;
general,.posting
of radiation areas;
general
control of step off pads,
disposal of protective
clothing, observation of calibration status of personnel
monitoring devices,
and Radiation
and Special
Mork Permits;
control
room manning;
discussions
were conducted with control
room operators
pertaining to reasons for selected
lighted annuciators;
security measures
associated
with the plant outage;
and,
verfication by use of an
NRC instrument
on a sampling
basis that radiation area posting
was consistent with
dose rate levels
IR
16
b.
THIS PAGE
HAS BEEN INTENTIONALLY DELETED; IT CONTAINED 10 CFR 2.790(d)
INFORMATION - NOT FOR PUBLIC DISCLOSURE.
17
14.
Exit Interview
The. inspector met with licensee
representatives
(denoted in paragraph
1) at the conclusion of the inspection
on December 6, 1979.
The
inspector
summarized
the scope
and findings of the inspection.-
The inspector
expressed
concern with the licensee's
program for
packaging
and shipment of low level radioactive waste.
The inspector
expressed
.the need for additional
management attention in this area
prior to future shipments of radioactive materials.
The 'licensee representatives
stated that to his knowledge
no shipment
of radioactive material
had left the facility prepared
in a manner
that would not.have afforded the designed
containment or had arrived
at its destination with radiation or contamination .levels in excess
of any applicable limits.
He also stated that the radioactive
material
shipping program is presently being upgraded
and that all
shipments
made during this period will be carefully scrutinized to
insure compliance is maintained with all applicable requirements.