ML18092B065
| ML18092B065 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/24/1986 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18092B062 | List: |
| References | |
| 50-272-86-05, 50-272-86-5, 50-311-86-05, 50-311-86-5, IEB-79-19, NUDOCS 8603270304 | |
| Download: ML18092B065 (10) | |
See also: IR 05000272/1986005
Text
. ' .
Combined
Report Nos.
Docket Nos.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/86-05
50-311/86-05
50-272
50-311
License Nos.
Priority ---
Licensee:
Public Service Electric and Gas Company
P.O. Box 236
Hancock's Bridge, New Jersey 08036
Facility Name:
Salem Generating Station
Inspection At:
Hancock's Bridge and Salem, New Jersey
Inspection Conducted:
February 24-28, 1986
Inspectors:
Approved by:
- u ~ /;/} _()
J'*lf.~
H. J.
1Bi cehouse, Radiation Speci a 1 i st
W. J. Pasciak~fluents Radiation
Protection Section
Category ---
c
date
Inspection Summary:
Inspection on February 24-28, 1986 (Combined Inspection
Report Nos. 50-272/86-05 and 50-311/86-05.
Areas Inspected:
Routine, unannounced inspection of the licensee's solid
radioactive waste preparation, packaging and shipping program.
Areas reviewed
included previously identified items, organization, indoctrination and train-
ing, quality assurance and implementation.
The inspection was conducted
on site and at the licensee's training facility in Salem, New Jersey.
Results:
One violation for failure to follow the provisions of a Certificate
of Compliance under 10 CFR 71.12(b)(2), one deviation for failure to provide
supplemental training to 2 QC inspectors as stated in response to NRC Bulletin
79-19 and one unresolved item related to radiological controls associated with
primary resin operations were noted during the course of the inspection.
8603270304-860324 -----,
ADOCK 05000272
G
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DETAILS
1.
Persons Contacted
During the course of this routine inspection, the following personnel
were contacted or interviewed.
1.1
Licensee Personnel
- J. M. Zupko, Jr., General Manager - Salem Operations
E.
Butler, Principal Training Supervisor
J.
Frick, Technical Supervisor - Radiation Protection
A.
Garrison, Nuclear Training Supervisor
- J.
Gomeringer, Technical Supervisor - Radiation Protection
B.
Hunkele, Senior Supervisor - Radioactive Material Control
- G. A. Livermore, Associate Quality Assurance Engineer
- L. K. Miller, Assistant General Manager - Salem Operations
D.
Parks, Training Supervisor
- D. A. Perkins, Manager, Salem Station Quality Assurance
- J. L. Rupp, Operations Licensing Engineer
D. S. Ruyter Training Coordinator
S. D. Simpson, Senior Supervisor - Technical
S.
Skabicki, Quality Control Supervisor
- J.
Trejo, Radiation Protection/Chemistry Manager
Other licensee
1 s personnel were also contacted or interviewed during this
inspection.
1.2
NRC Personnel
- T. J. Kenny, Senior Resident Inspector
- L. J. Norrholm, Chief, Reactor Projects Section No. 28
- Attended the Exit Interview on February 28, 1986.
2.
Purpose
The purpose of this routine inspection was to review the licensee 1 s
radioactive waste (radwaste) preparation, packaging and shipping program
with respect to the following elements:
Status of Previously Identified Items;
Organization;
Indoctrination And Training;
Quality Assurance Program; and
Implementation.
3.
Previously Identified Items
4.
3.1
3.2
3
(Closed) Inspector Followup Item (50-272/84-40-01)
Review
reorganization of Radwaste Group.
The license completed a
reorganization which placed a Senior Technical Supervisor in charge
of radwaste and created two new Technical Supervisory positions
responsible for specific operations (See Detail 4).
This item is
closed.
(Closed) Inspector Followup Item (50-272/84-40-02)
Review Quality
Assurance audits of the transportation program.
Audit No. NS-85-056,
11 Radwaste Program - Salem Nuclear Departme~t (conducted 6/24-28/85)
was reviewed for inclusion of 10 CFR 61 and 10 CFR 71, Subpart H
elements applicable to the licensee
1 s packaging and shipping program.
The audit reviewed appropriate attributes of the radwaste program.
A
Quality Assurance Auditor and a contracted technical specialist
conducted the audit.
This item is closed.
Organization
The organization of the licensee 1 s program for meeting waste generator
requirements under 10 CFR 20.311 and 10 CFR 61 and packaging and shipping
requirements under 10 CFR 71 was reviewed relative to technical specifi-
cations and commitments in the licensee 1s Updated Final Safety Analysis
Report.
The licensee
1 s performance relative to the specifications and
commitments was determined by interviews of the Senior Supervisor-Radio-
active Material Control and members of his staff and review of Adminis-
trative Procedure (AP) 29,
11 Radioactive Waste And Material Control Pro-
gram, Revision 2 (11/20/84).
Within the Radiation Protection/Chemistry Department, the Radiation
Protection Engineer (RPE) oversees all aspects of the solid radwaste
program through the Senior Supervisor-Radioactive Material Control.
The
inspector noted that the RPE position was vacant.
The Senior
Supervisor-Radioactive Material Control functions as the administrative
radwaste coordinate~ responsible to:
maintain current copies of Department of Transportation (DOT) and
NRC regulations concerning packaging, transfer and transport and
Agreement State Licensee and Waste Burial Site regulations;
maintain current copies of user manuals, Certificates of Compliance
and Letters of Authorization for each type of radwaste shipping
container used by the station;
provide appropriate procedures concerning radwaste activities;
review instructions used to transfer, process, package and release
radioactive material from the station; and
ensure that training/retraining programs are developed and
implemented for individuals involved in day-to-day processing of
solid radwaste.
4
Two Technical Supervisors, reporting to the Senior Supervisor Radioactive
Material Control provide supervision of the Radiation Protection Staff
assigned to radwaste operations.
The inspector noted that AP-29 did not
reflect the reorganized Radiation Protection/Chemistry Department and
failed to delineate the duties and responsibilities of the two Technical
Supervisors.
Within the scope of this review, no violations were noted.
5.
Indoctrination And Training
The licensee's program for indoctrination and training of personnel
involved in solid radwaste preparation, classification, packaging and
shipping operations was reviewed relative to criteria and commitments
provided in:
Technical Specification 6.3, "Facility Staff Qualifications";
Technical Specification 6.4, "Training";
ANSI Nl8.1-971, "Selection And Training Of Nuclear Power Plant
Personnel"; and
Licensee's letter (dated 9/25/79) from F. W. Schneider, Vice
President, Production to B. H. Grier, Director, NRC-Region I in
response to NRC Bulletin No. 79-19, "Packaging Of Low-Level
Radioactive Waste For Transport And Burial", (8/10/79).
The licensee's performance relative to the criteria and commitments was
determined by:
interviews and discussions with the Senior Supervisor-Technical, the
Senior Supervisor-Radioactive Material Control and members of his
staff, the Quality Control Supervisor, the Principal Training Super-
visor and the Nuclear Training Supervisor and memb~rs of her staff;
review of Radiation Protection (RP) Procedure 2.001, "Radiation Pro-
tection Qualification Program, Revisions (10/18/85) and GM 9 Quality
Assurance Procedure (QAP) 1-5, "Personnel Training, Qualification And
Certification, Revision 3 (11/18/85); and
examination of training records for courses related to solid
radwaste shipping provided onsite, at the Salem, New Jersey Training
Facility and offsite by various vendors.
Wi.thin the scope of this review, the following apparent deviation from
licensee commitments was noted:
In response to NRC .Bulletin No. 79-19, the licensee stated, in part,
that a supplemental program for training and retraining in DOT and NRC
Regulations, waste burial requirements and procedures and instructions
for those personnel involved with transfer, packaging and transport of
radioactive material would be developed by January 1, 1980 and
implemented by April 1, 1980.
Quality Control (QC)Inspectors provide
review of the licensee's radwaste packaging and shipping activities and
1
6.
5
concur in procedural steps ("Inspection Hold Points") critical to
successful packaging and shipping.
In 1980, the licensee provided
training to personnel involved in transfer, packaging and shipping
activities (including QC Inspectors).
Following revisions to DOT and NRC
Regulations in 1983, the licensee provided a supplemental training course
for QC Inspectors including approximately two hours on radwaste shipment
inspections.
Review of training records for this course indicated that
two QC Inspectors providing concurrence in procedural steps for licensee
Shipments Numbers 85-5, 85-16, 85-26, 85-27 and 85-28 had not attended the
supplemental training course.
The licensee did not identify any other
training sessions for those two QC Inspectors.
Failure to provide
supplemental training to the two QC Inspectors involved in the above
radwaste shipments constitutes an apparent deviation from commitments
made by the licensee in response to NRC Bulletin No. 79-19,
50-272/86-05-01; 50-311/86-05-01.
Quality Assurance Program
A Quality Assurance program is required for transport packages in
accordance with the provisions of 10 CFR 71, Subpart H.
A commission
approved Quality Assurance program which satisfies the applicable
criteria of Appendix B of 10 CFR 50 and which is established, maintained
and executed with regard to transport packages is acceptable to meet the
requirements of 10 CFR 71, Subpart H.
The licensee elected to apply
their currently established 10 CFR 50, Appendix B Quality Assurance
program to the packaging and transportation of radioactive materials.
In addition to the general Quality Control (QC) provisions required by 10
CFR 50, Appendix B, specific QC requirements to assure compliance with 10
CFR 61.55 and 61.56 are. required by 10 CFR 20.311.
Specific QC of rad-
waste processes is also required by Technical Specification 6.13, "Process
Control Program (PCP)".
6.1
Radwaste Geneiator QC Program
The licensee's performance in conducting a quality control program
under 10 CFR 20.311 (d) (3) and Technical Specification 6.13 was
determined by review of procedures for preparing radwaste shipments,
examination of records related to shipments of dewatered resins and
solidified waste liquids, independent determination of waste
classification for selected shipments and discussion with the Senior
Supervisor-Radioactive Material Control and a member of his staff.
Within the scope of this review, the following items were noted:
Samples from the licensee's dry active waste, resins, oil,
evaporator bottoms, sludge, primary resins and filters were
sent to a contractor for analysis.
...
6
A vendor's Process Control Program for the solidification of
oils was reviewed, incorporated into the licensee's procedures
and implemented.
Specific Inspection Hold Points related to dewatering and/or
solidification were provided in licensee procedures.
A verified computer program was used for waste
classifications.
However, RP 7.037, ("Operating Instructions
For RADMAN", Revision 0, 12/21/83) described the use of a Tandy
TRS-80, Model 12 Computer system.
The licensee had switched to
an IBM PC and had not updated RP 7.037 to incorporate changes
in operating instructions for the waste classification
program.
The inspector noted that the Radiation Protection
staff was being instructed on the use of the new computer-based
program and no radwaste shipments had been made since the
change in computers.
6.2
QC Inspection Activities
The site QC organization provides inspections of packaging and
shipping activities.* The licensee's inspection procedures were
reviewed and discussed with cognizant QC personnel.
Selected
packaging and shipping procedures were reviewed for appropriate
Inspection Hold Points.
Within the scope of this review, no violations or concerns were
identified.
The inspector noted that QC Instructions governing this
activity were under development.
6.3 Surveillance Activities
The site Quality Assurance organization provides periodic surveil-
lance of radwaste management activities including QC activities.
Four quarterly surveillances were reviewed and discussed with the
Associate Quality Assurance Engineer.
Within the scope of this review, no violations or concerns were
identified.
6.4 Audits
The licensee's program for audits of radwaste preparation,
classification, packaging and shipping activities was reviewed (see
related item Detail 3.2). The findings (and their disposition) of
Audit No. NS-85-056 were reviewed.
The inspector noted that audit
findings had been evaluated by licensee management (as required by
10 CFR 20.311 (d) (3)).and dispositioned in an appropriate manner.
Within the scope of this review, no violations were identified.
. * .. :: _._.*, ..
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- 7.
7
Implementation
During 1985, the licensee made 52 shipments of radioactive materials
including solid radwaste shipments.
A sample of 18 radwaste shipments
was selected and reviewed against criteria provided in:
10 CFR 61.55 and 61.56;
49 CFR, 170-189;
11 Procedures And Programs
11 ;
11 Record Retention
11 ; and
11 Process Control Program 11 *
7.1 Waste Generator Requirements
The following waste generator requirements were reviewed and
discussed with the licensee:
Waste Manifests under 10 CFR 20.311 (d) (4) and 10 CFR 20.311
(b) and (c);
Waste classification under 10 CFR 20.311 (d) (1);
Waste Form And Characterization under 10 CFR 20.311 (d) (1) and
Waste shipment labeling under 10 CFR 20.311 (d) (2) and 10 CFR
61.55;
Tracking of waste shipments under 10 CFR 20.311 (d), (e), (f),
and (h); and
Disposal site License Conditions.
In each instance, procedures governing the activity and
representative waste shipment records were reviewed.
Within the scope of this review, no violations were identified.
7.2 Procurement And Selection Of Packagings
The licensee 1 s program for the selection of packages was reviewed
against the requirements of 10 CFR 71.12,
11General License:
NRC
Approved Package
11 and the DOT requirements of 49 CFR 173,
11Shippers-General Requirements For Shipments And Packagings 11 *
The licensee 1 s performance relative to there criteria was determined
by interviewing the Senior Supervisor-Radioactive Material Control
and members of his staff, examination of licensee procedures and
review of appropriate shipping records.
Within the scope of this review, the following violation was noted:
t
8
10 CFR 71.12 (b) (2) requires, in part, that each licensee comply
with the terms and conditions of the Certificate of Compliance (CDC)
issued by the NRC in order to deliver an approved package to a -
carrier for transport.
CDC Number 6601, governing the general
licensed use of Mo-del CNSI 8-120 Radioactive Material Shipping
Packages requires, in part, that the packaging be leak tested once
every 12 months in accordance with the supplier 1 s application for a
CDC.
Contrary to these requirements, the licensee made the following
shipments in Model CNSI 8-120 packages during 1985 and did not
verify the completion of a suitable leak test by the package vendor
during the 12 month period preceding the shipment: -
Shipment No.
Dates
Total Activity (curies) Material Shipped
85-22
04/09/85
420
Primary resin
85-26
05/01/85
420
Primary resin
85-34
08/28/85
32
Dry filters
85-43
10/15/85
310
Dewatered resin
85-47
10/28/85
190
Dewatered resin
Licensee 1 s procedure RP 7.015,
11Use of the CNSI 8-120 Radioactive
Material Shipping Package
11 , failed to provide instructions
concerning verification of a suitable leak test.
The licensee stated that verbal verifications of completion of a
suitable leak test were usually completed prior to shipment but was
unable to verify that verbal verification had been completed for
each of the above shipments.
On February 26, 1986, the licensee
revised RP 7.015 to fequire recording of the completion of a
suitable leak test prior to each use of the Model CNSI 8-120
package.
Failure to verify the completion of a suitable leak test
during the 12 month period preceding the 5 shipments constitutes a
violation of 10 CFR 71.12 (b) (2).
50-272/86-05-02; 50-311/86-05-02.
7.3 Preparation of Packages For Shipment
The licensee 1 s program for the preparation of packages for shipment
was reviewed against the requirements of 49 CFR Parts 172 and 173,
11Shippers-General Requirements For Shipments And Packagings, 10 CFR
71.87,
11 Routine Determinations
11 and Technical Specifications 6.8,
6.10 and 6.13.
The licensee 1 s performance relative to these criteria was determined
by interviews of the Senior Supervisor-Radioactive Material Controls
and members of his staff, examination of procedures and other
documents and observation of handling, storage and loading areas of
the site.
..
9
Within the scope of this review, the following unresolved item was
noted:
Demineralizer resins are used to maintain the water quality of the
primary reactor coolant loop.* Those resins are collected in a resin
tank at the end of their useful life and transferred to high
integrity containers for dewatering and shipping to an authorized
burial site.
The spent resins contain hundreds of curies of
radioactivity necessitating strict control of their handling,
packaging and shipment to prevent high radiation exposures to plant
and transport personnel and accidental release to the plant
environs.
Three shipments of spent primary resins were made during April-May
1985 totalling 1050 curies of total activity.
The resins were
transferred to high integrity containers in an area of the Auxiliary
Building (i.e.,
11 Demin Cage
11 on 100 foot elevation) and dewatered.
The high integrity containers were transferred to Model CNS! 8-120
containers and sent for disposal as licensee Shipments Numbers
85-22, 85-25 and 85-26.
Review of shipping records, interviews of licensee personnel and
observations of the work area indicated:
Radiation levels ranging from 10 to 200 rads per hour (R/hr)
were recorded for high integrity container Serial Number
432030-38 on April 8, 1985 during Shipment Number 85-22.
License personnel apparently entered the high radiation area to
conduct surveys, verify dewatering of the resins and place and
secure the lids to the high integrity containers.
Personnel monitoring devices on the individuals may have been
located on the trunk of their bodies at a location partially
shielded from the radiation fields encountered by the head,
arms and upper trunk and thus, unable to record the radiation
exposures to those areas accurately.
Spills of resin during filling or transfer of high integrity
containers could result in high airborne radioactivity
exposures to workers and unmonitored release to the plant
environs through the truck doorway area.
At the exit interview on February 28, 1986, the licensee's
representative acknowledged the safety concerns and stated that a
task force was reviewing a proposed change to a
11 zero release
11
operating mode.
Part of this operating mode would require the use
of long-life high retention filter demineralizer resins in the
primary reactor coolant loop.
The use of long-life resins would
necessitate upgrades to handling facilities used for disposal of
.. 1
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10
those resins since their contained activity would be higher than
current resins.
The licensee's representative also stated that the
licensee's radiation protection personnel would evaluate interim
upgrades to the radiological controls associated with primary resin
operations, (e.g., audible~alarming dosimeters, standing Radiation
Work Permit requirements and other administrative controls).
The
adequacy of radiological controls associated with primary resin
transfer, dewatering, container preparation and movement in the
"Demin Cage" is unresolved pending further review by NRC Region 1.
50-272/86-05-03; 50-311/86-05-03.
7.4 Delivery Of Packages To Carriers
The licensee's procedures for delivering packages to carriers were
reviewed against criteria provided in:
10 CFR 71.5 (a) (1) (iii), "Placarding";
10 CFR 71.5 (a) (1) (vi), "Shipping Manifest";
10 CFR 20.311 (b), "Shipping Manifest";
10 CFR 20.311 (c), "Certification"; and
10 CFR 71.5 (a) (2) (iv), "Public Highway - 49 CFR Part 177
11
The licensee's performance relative to these criteria was determined
by review of procedures and shipping records and discussions with
cognizant licensee personnel.
Within the scope of this review, no violations were identified:
8.
Exit Interview
The inspector met with the licensee representatives (denoted in Detail 1)
at the conclusion of the inspection on February 28, 1986.
The inspector
summarized the scop_e of the inspection and findings at that time.
At no time during this inspection was written material provided to the
licensee by the inspector.
No information exempt from disclosure under
10 CFR 2.790 is discussed in this report.