ML18096A152
| ML18096A152 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/12/1991 |
| From: | Joseph Furia, Nimitz R, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A150 | List: |
| References | |
| 50-272-91-13, 50-311-91-13, 50-354-91-11, NUDOCS 9107290202 | |
| Download: ML18096A152 (17) | |
See also: IR 05000272/1991013
Text
..
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-272/91-13
50-311/91-13
50-354/91-11
Docket Nos. 50-272
50-311
50-354
License Nos. DPR-70
Licensee:
Public Service Electric and Gas Company
P.O. Box 236
Hancocks Bridge, New Jersey
Facility Names:
Salem Nuclear Generating Station, Units 1 and 2
Hope Creek Nuclear Generating Station
Inspection At:
Hancocks Bridge, New Jersey
Inspection Conducted :
May 13-17, 1991
Inspectors:
J.
ria, Senior Radiation Specialist
Approved by: W G02 C-~.)_
W. Pasciak, Chief, Facilities Radiation
Protection Section
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Inspection Summary: Inspection on Mav 13-17. 1991 (NRC Combined Inspection Report
Nos. 50-272/91-13; 50-311/91-13; 50-354/91-11) .
Areas Inspected: This was a routine, unannounced inspection of the licensee's radioactive
waste collection, handling, storage, and transportaion programs. Areas reviewed were:
9107290202 910617
ADOCK 05000272
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2
audits and appraisals, changes in personnel, facilities, or programs, training and
qualifications, solid radwaste implementation, scaling factor determinations, on-site
storage of radioactive material, and shipment records and procedures.
Results : Within the scope of this inspection, one violation was identified. The violation
involved one example of failure to implement the license verification requirements of 10
CFR 30.41. (Details are in Section 9.1).
L
DETAILS
1.0
Individuals Contacted
1.1
Public Service Electric and Gas Company
- T. Cellmer, RP/Chem Manager, Salem
- P. Duca, Delmarva Site Representative
- R. Hovey, Operations Manager, Hope Creek
- W. Hunkele, Senior RP Supervisor, Salem
- E. Karpe, Radiation Protection Supervisor, Hope Creek
- E. Katzman, RP Services Principal Engineer
- E. Krufka, Atlantic Electrical Site Representative
- S. LaBruna, Vice President Nuclear Operations
- M. Prystupa, Radiation Protection Engineer, Hope Creek
- D. Ruyter, Senior RP Supervisor, Salem
- E. H. Villar, PSE&G Licensing Engineer
- C. Vondra, PSE&G General Manager Site Operations
- J. Wray, Radiation Protection Engineer, Salem
1.2
NRC Personnel
>t- T. Johnson, NRC Senior Resident Inspector
- S. Barr, NRC Resident Inspector
The inspectors also conracted other licensee and contractor individuals during the
course of this inspection.
- Denotes those personnel attending the exit meeting on
May 17, 1991.
2.0
Purpose and Scope of Inspection
The purpose of this routine inspection was to review the licensee's programs for
radioactive waste collection, handling, and storage and for the proper preparation,
packaging, and shipment of licensed radioactive material.
3.0.
Quality Assurance (QA) and Quality Control (QC)
The inspectors reviewed the licensee's QNQC program. The review was with
respect to criteria contained in 10 CFR 20.311, 10 CFR 61.55, 10 CFR 61.56 and
applicable Technical Specifications.
4
3.1
Qualitv Assurance Audits - Salem and Hope Creek Stations
The inspector reviewed the latest audit, NQA Audit Report 90-150, dated July 17,
1990. The scope of this latest audit was broad covering both Salem and Hope
Creek stations as well as both radiation protection and* radwaste/transportation
topics. The qualifications of the audit team members was reviewed. There was
good technical depth represented for the radwaste/ transportation area. The audit
was comprehensive and sampled the important subject areas. One technical
finding was associated with the use of the RADMAN computer program. One of
. the program menu options allows for a natural logarithmic averaging of
radioisotopes which is in conflict with the recommended arithmetic averaging of
radionuclides based on volume content in a shipment. This finding was followed
and appropriately closed out on August 3, 1990.
The _basic J'echnical Specification requirement for a biennial Process Control
Program audit was extended to any and all vendors which supply any services as
described in 10 CFR 71, Subpart H. Chem Nuclear Services has been used for
processing of waste resins and for transportation services. The inspectors .
reviewed Nuclear Utilities Procurement Issues Council (NUPIC) audit no. SNA 91-001. The audit was performed November 13 - 16, 1990 by Nebraska Public
Power District and was a very comprehensive review of Chem Nuclear's broad
s_cope of service offerings. One of the findings related to subtier vendors who
provide safety related items not being listed on Chem Nuclear's approved vend.ors
. list. The specific findings .had been addressed in return correspondence from
Chem Nuclear. The vendor audit area was satisfactorily fulfilled.
3.2
ONOC - Salem and Hope Creek Stations
The inspectors reviewed the extent of ONQC surveillance of radwaste. shipping
activities at the Salem and Hope Creek stations. The inspectors also reviev>'ed the
training and qualification of QNQC personnel performing oversight of radwaste
shipping activities. The review was with respect to applicable criteria contained in
the licensee's. procedures, 10 CFR 71, Packaging and Transportation of
Radioactive Material, and IE Bulletin 79-19. The. evaluation of the licensee's
performance in this area was based on discussions with cognizant licensee
personnel, review of applicable records and independent review of on-:going
shipping activities.
The licensee performs 100% surveillance of all shipments with the exception of
laundry shipments. Laundry shipments are reviewed periodically. QNQC
surveillance check lists were developed for the surveillances.
_The licensee's Salem Station personnel are responsible for coordinating all
radwaste shipments from Artificial Island. However, QNQC personnel from each
.
5
respective station (Salem.or Hope Cree-k) provide the direct QNQC oversight for
that particular station.
-
Each individual who is authorized to perform QNQC oversight of radwaste
shipping activities was qualified via a training and qualification program. A
qualification card is signed off for each QNQC inspector by an appropriately
qualified individual. The licensee provided on site training of QNQC personnel
by a vendor on radwaste activities. The licensee also provided training on changes
to regulatory requirements. A formal course on radwaste shipping activities was
given at the training center and training updates were provided periodically to
appropriate personnel. Annual re-training is provided to meet the requirements
of IE Bulletin_ 79-19. An annual performance evaluation, which includes a
supervisor sign-off, was made of QNQC personnel performing oversight of
radwaste shipping activities. The licensee maintains a posted matrix of the
qualifications of QNQC personnel performing radwaste shipping activity oversight.
The licensee developed and implemented a generic check list to evaluate work
practices. The inspector noted there was no checklist for radwaste storage
activities. The licensee's personnel indicated such a check list would be
developed.
The inspectors reviewed -the Hope Creek QNQC ins-pectors qualifications and _
_ verified specific radwaste shipping training and annual retraining requirements
were met. A QNQC shipment checklist was used for verification of each
shipment leaving Hope Creek Station. The inspector reviewed ten (10)
radioactive material or radwaste shipment QNQC surveillances from 1991. The
surveillance reports were complete with no significant discrepancies noted.
No violations were identified. The licensee was performing generally good
QNQC oversight of radwaste shipping activities.
-
4.0
Changes ..: Organization, Facilities, Programs
The inspectors reviewed. radwaste/transportation related changes relative to 10
CFR 50.59 for any unreviewed safety issues.
4.1
Organization
At both Salem and Hope Creek Stations, the radiation protection departments
provide the packaging and shipping functions for radioactive material and
radwaste. There have been two changes in personnel since the last
radwaste/transportation inspection. The previous Radiation Protection (RP).
Engineer (i.e., radiation protection manager) for Hope Creek Station, took on the
4.2
4.3
"6
role of Salem Radiation Protection/Chemistry Manager towards the end of 1990.
The previous Hope Creek Chemistry Manager, filled the Hope Creek RP
Engineer position at the same time frame. Both individuals are well qualified for
these new positions .with no apparent negative affects attributed to these changes.
Otherwise, the radwaste/transportation organizations have remained stable since
the last inspection in this area.
Facilities
The Salem Generating Station continues to use vendor services for processing of
plant liquid wastes and for dewatering and drying of resins in High Integrity
Containers (HICs).
The Hope Creek Generating Station has used its asphalt extruder/evaporator
waste solidification system for approximately one year since plant startup. Due to
various radwaste system problems, the station has used Chem Nuclear vendor
services for processing of liquid wastes and dewatering and drying of resins from
approximately March 1990 until April 1991. Currently the asphalt
extruder/evaporator system is in service. Hope Creek remains to startup a
radwaste evaporator and CI)'Stallizer for processing of floor drain wastes. No
significant safety issues were noted.
Programs
Both Salem and Hope Creek stations utilize the RADMAN (WMG,Inc.)
computer code for radioactive shipment classification and shipment manifest
generation. The licensee stated that the RADMAN program assumes the use of
single container packages (e.g., HI Cs) in its calculations. The asphalt
extruder/evaporator system produces stable wastes in 55 gallon drums and typically
fourteen (14) of such drums comprise a shipment package. The licensee
contracted with WMG, Inc. to write an additional computer program which would
accept multiple source container input as a front end of the original RADMA.t~
program. In the summer of 1989 this program was completed and the licensee
validated the computer calculations using data from two (2) shipments. The
inspector examined these validation tests and found excellent agreement between
the computer generated results and the manually derived results. The inspector
was satisfied that there was no departure from the original use of the RADMAN
program.
5.0
Training and Qualifications
The inspector reviewed the licensee's radwaste/transportation training program
against the regulatory guidance contained in IE Bulletin 79-19. The licensee's
training program as it affects radwaste/transportation is divided into three (3)
5.1
7
parts: radiation protection technician training common to Hope Creek and Salem
stations, Salem Nuclear Equipment Operator (NEO) training, and Hope Creek
Radwaste Equipment Operator (REO) training. Lesson plans were examined and
training records for selected personnel were reviewed against IE Bulletin 79-19
requirements. In addition, the Radiation Worker Training lesson plan was
reviewed for radwaste minimization content.
Radiation Protection
The inspector reviewed Lesson Plan No. 45004-LES002-00 entitled, "RP
Technician Radioactive Material Control Shipment/Receipt of Radioactive
Material Shipment/Receipt of Radioactive Materials". This 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> course is
given to all RP technicians as initial training. The course content was considered
good. To address the periodic retraining requirement, the licensee offers a six (6)
hour course for all RP Technicians, Lesson Plan No. 49989-LESOB-OO
entitled,"Radwaste Packaging and Shipping Regulations". This course content was
also considered good. The inspector reviewed with the licensee the requirements
for radiation protection personnel to receive radwaste/transportation training. All
RP technicians are required by training procedure TP-400 to receive the
appropriate training. The requirement for training of supervisors was addressed
generally by reference to a March 22, 1990 licensee letter no. NTD-90-5073 which
summarized the results from a radiation protection/chemistry meeting where
agreement was reached that all RP and chemistry supervisors will attend certain
continuing training courses with technicians. Specific courses were to be
determined later. This will be reviewed in a later inspection. Training records for
six (6) selected supervisors and technicians were reviewed and found complete.
5.2
Salem Nuclear Equipment Operator (NEO)
All Salem NE Os are required to receive four ( 4) hours of "Radioactive Waste
Liquid" training (Lesson Plan No. 3015-000.005-RWLOOl-Ol). This course
provides instruction in startup and shutdown of the waste evaporator, transfer of
waste evaporator concentrates, alignment of waste holdup tanks to auxiliary
processing systems and placing auxiliary processing systems into service. Training
records for six (6) selected radwaste operators were reviewed and found complete.
5.3
Hope Creek Radwaste Equipment Operator (REO)
The Hope Creek REOs receive a two (2) hour course on the "Process Control
Program", Lesson Plan No. 301H-OOO.OOH-OOHC06-02. This course adequately
covers the Solid Waste Management System (SWMS) process control parameters.
Training records for five (5) REOs were reviewed and found to be complete. -
8
5.4
Radiation Worker
IE Bulletin 79-19 indicates that any power plant worker who generates, transfers,
or processes radioactive waste shall receive radwaste minimization training. All
radiation workers at both stations are given Radiation Worker Training on an
annual basis. Lesson Plan No. 202-100-001-08 was reviewed and found to contain
excellent radwaste minimization subject material both in scope and depth.
In general, the licensee's training program was of appropriate scope and of
adequate depth.
6.0
Solid Radwaste Implementation
Final Safety Analysis Report (FSAR) and Process Control Program (PCP)
documents for both stations were reviewed against current plant practice.
Hope Creek Generating Station utilizes an asphalt extruder/evaporator system for
solidification to a stable waste form. The Hope Creek Process Control Program
calls for the control of four (4) process parameters: process temperature in six (6)
heat zon.es, asphalt type, mixture ratio (waste to asphalt), and oil content. During
asphalt waste solidification processing: the inspector verified the appropriate
controls and that operations were within limits for each parameter. Hope Creek
remains to startup a waste evaporator and a crystallizer. The systems that are in
operation are being operated in accordance with NRC approved documents.
Salem Generating Station has contracted a vendor supplied liquid waste
processing and resin dewatering service instead of the plant cement solidification
system as described in FSAR section 11.5.2. Also, current plant practice involves
offsite vendor incineration of oil. The Salem Process Control Program, Rev. 1,
section V, specifies oil solidification as the only option for disposal. Both the
FSAR and PCP documents are in need of updating. There is no safety
significance to the above omissions.
7.0
Radioactive Material and Contamination Control
The inspector toured the Salem and Hope Creek Station periodically during the
inspection and reviewed the licensee's controls for radioactive material and
contamination. The review was with respect to criteria contained in 10 CFR 20,
and applicable licensee procedures. The following matters were reviewed:
posting, labelling, and control of radioactive and contaminated materials;
personnel use of contamination control devices.
9
The evaluation of the licensee's performance in this area was based on review of
on-going work activities, discussions with personnel and review of documentation.
The following positive observations were made:
The licensee has been aggressively pursuing reduction- in the square footage
of contaminated floor space at the station. The inspector observed
improved plant appearance as a result of painting and cleaning efforts.
Currently about 6.3 % of Salem station floor space is contaminated
(excluding containment). The Hope Creek Station, as of December 31,
1990, had about 5% of its applicable surface indicated as contaminated.
These values compare favorably with industry averages.
The Salem Station personnel have developed a hot spot tracking program
to identify and plan efforts to decontaminate hot spots on plant piping.
The Salem Station personnel have developed a radiological controlled area
leak -tracking program to track and monitor progress on repair of leaking _
valves.
The licensee has been documenting low level personnel contaminations and
reviewing the individual events in order to improve personnel
contamination controls.
8.0
Radioactive Material Storage and Minimization
The inspector reviewed the storage of radioactive material. The review was with
respect to criteria contained in 10 CFR 20, applicable licensee procedures and
NRC Generic Letter Br-38. The evaluation of the licensee's performance in this
area was based on discussions with cognizant personnel, review of applicable
records and observations during plant tours of the Salem and Hope Creek
Stations.
-
8.1
Salem
The method of handling and storage is commensurate with the quantity of
radioactive material contained in the waste and the level of radiation dose rates
emanating from the waste.
Dry Active Waste (DAW) consisting of various materials (e.g., mop heads, paper, -
rags,) that exhibit low radiation dose rates was collected from waste bins
throughout the radiological controlled area (RCA), transferred to a central
collection point within the Radwaste truck lock, then transferred to sea-vans for
shipment to a vendor for super compaction and subsequent burial. Because the
10
generated volume has been low, the licensee has not found it necessary to
segregate potentialiy clean waste from contaminated waste. The licensee believes,
based on a cost benefit analysis, that it would not be _cost beneficial to segregate
potentially clean waste from potentially contaminated waste at the Salem Station.
Spent primary coolant resins are sluiced to a holding tank for de-watering and
packaging in a high integrity container for off site shipment and burial. The
licensee has been able to operate from 12-18 months on a single batch bf primary
resin.
The licensee does not use the installed liquid radwaste processing system. Rather,
the licensee has installed a vendor supplied liquid processing system. The system
uses ion specific resin to clean up the liquid. The use of the system has resulted
in a significant reduction of volume for off site shipment. A resin charge for the
v_endor system lasts about two years.
_ The licensee does not have any abandoned radwaste processing systems that
present a hazard. The installed solidification system is not used. The licensee
does not allow radwaste to accumulate. The licensee has cleaned out unnecessary
material from the Unit 2 spent fuel pool and plans to clean out unnecessary
material from the Unit 1 pool.
The licensee stores various mechanical filters (e.g., reactor coolant filters, spent
fuel pit filters) in a locked area of the radwaste building.
The transfer of the mechanical filters to storage was facilitated by use of a
specially designed shielded cask. The licensee's use of the cask reduces personnel
radiation exposure during the transfer. The filters are allowed to air dry and are
then placed in a special shipping container for off site disposal.
Potentially contaminated miscellaneous liquid waste (e.g., oil) is collected,
transferred, and stored in designated locations. The oil is analyzed then shipped
to an off site vendor for incineration.
Based on the above review, the inspector concluded that the licensee provided
adequate controls for collection, handling, and storage of radioactive waste.
Adequate procedures have been developed. Review of the licensee's recent
history of radwaste volumes transferred for burial indicated that good efforts were
made by the licensee to reduce radwaste volumes buried.
8.2
Hope Creek
The licensee's radwaste program provides for separate collection, handling and
processing of potentially contaminated and clean waste. Separate collection bins
are provided in the RCA. Material with any indication of contamination or
. '
11
material which has inaccessible surfaces is processed as radioactive waste. The
licensee's program for segregation and release of waste as clean waste was
established consistent with applicable NRC guidance.
The licensee does not routinely process mechanical filters. The licensee will
provide for controlled storage and drying of the filters. The filters would be
subsequently shipped off site for disposal.
The licensee collects spent resins from various liquid waste processing systems.
The resins are stored in designated storage tanks. The resins are subsequently
solidified using an asphalt extruder/evaporator process prior to being shipped off
site for disposal.
Oil and other miscellaneous liquid waste is collected and stored in designated
storage locations. After appropriate sampling and analysis, the oil is shipped off
site for subsequent incineration. Non-oil waste is processed as .appropriate.
There are no abandoned radwaste systems at Hope Creek. Radwaste is not
allowed to accumulate. There is limited material stored in the spent fuel pool.
The licensee plans to clean out and ship the material off site for disposal. Based
on the above review, the inspector concluded that the licensee provided adequate
controls_ for collecting, handling, and storage of radioactive waste.
The inspector noted that the licensee was using hand held friskers to perform
individual surveys of material and equipment, including clean trash, leaving the
RCA. The licensee was performing a final aggregate check of the clean trash
using a hand held survey meter ( micro-R meter). This was consistent with
applicable NRC guidance. The inspector noted however, that the licensee was
using a 10% detection efficiency for the frisker probe based on a study that had
been previously performed.
The inspector requested the licensee to perform a quantitative check of the
efficiency. The licensee's test, using a smear from a contaminated area (chemistry
sample sink), indicated the frisker had an efficiency on the order of about 2.5%.
The licensee believed that Zn-65, which is injected into the primary system to
reduce overall plant system radiation dose rates, was not being readily detected by
the frisker resulting in a lower quantitative efficiency than previously selected.
Subsequent licensee reviews indicated that the frisker efficiency generally ranged
from about 6% to 14% depending upon the location where the smear was
collected.
The inspector noted that the licensee's surveys of aggregate clean trash with the
micro-R meter provided reasonable assurance that undetected radioactive
contamin_ation was not leaving the RCA via the clean trash route. In addition, the
licensee's whole body friskers were capable of seeing Zn-65 contamination on
12
licensee's whole body friskers were capable of seeing Zn-65 contamination on
workers as determined by a previous licensee study. However, the licensee relied
on the frisker for checking of individual hand held items at the single RCA exit
point.
To ensure undetected low level Zn-65 contamination was not exiting the RCA via
the RCA exit point, the licensee enhanced the monitoring of articles for low level
gamma emitters. This included surveying articles with gamma sensitive probes
and analysis of smear samples by gamma spectroscopy. These measures were
considered by the licensee to be interim pending the licensee's full evaluation of
frisker efficiencies. Preliminary evaluation by the licensee did not indicate a
problem with undetected Zn-65 leaving the RCA via the RCA exit point.
The licensee has initiated a program to periodically evaluate its contamination
control program to detect changes which may necessitate changes in the
contamination monitoring program. The licensee's evaluation will be reviewed
during a subsequent inspection.
9.0
Transportation
The inspectors reviewed the licensee's radioactive material shipment programs in
accordance with 10 CFR 20.311, 10 CFR 30, 10 CFR 61, 10 CFR 71, and the
. Low-Level Waste Licensing Branch Technical Position On Radioactive Waste
Classification (May 1983).
9.1
Radwaste Shipping - Salem
The inspector reviewed the licensee's preparation for shipment of a reactor
coolant pump motor to an off site vendor company. The inspector made
independent measurements of radiation dose rates of the motor and reviewed
applicable shipping documentation. The motor exhibited low levels of radioactive
contamination.( 19 micro-curies) and was packaged in a specially constructed
strong tight container.
The inspector's review indicated the vendor that was to receive the motor
(transferee) had an apparent expired license as indicated by the copy of the
vendor's license contained in the licensee's files. The licensee's copy of the
vendor's license (Amendment 12) was dated August 30, 1990. The shipment was
scheduled for May 14, 1991.
The inspector noted that 10 CFR 30.41 ( c) states, in part, that before transferring
by-product material to a specific licensee of the commission, the licensee
transferring the material (transferor) shall verify that the transferee's license
authorizes the receipt of the type, form, and quantity of b;:-product material to be
13
transferred. 10 CFR 30.41 ( d) provides five methods acceptable to the NRC for
verification as follows:
- ( 1)
The transferor may have in his possession, -and read, a current copy of the
transferee's specific license;
(2)
The transferor may have in his possession a written certification by the
transferee that he is authorized by license or registration certificate to
receive the type, form, and quantity of by-product material to be
transferred;
(3)
For emergency shipments,the transferor may accept oral certification by the
transferee that he is authorized by the license or registration certificate to
receive the type, form, and quantity of by product material to be
transferred, provided that the oral certification is confirmed in writing
within 10 days;
( 4)
The transferor may obtain other sources of information compiled by
reporting services from official records by the Commission or the licensing
ag~ncy of an Agreement State as to the identity of licenses and the scope
and expiration date of licenses and registration; or
(5)
When none of these methods of verification described above are readily
available or when a transferor desires to verify that information received by
one of the above methods is correct or up-to-date, the transferor may
obtain and record confirmation from the Commission or licensing agency of
an Agreement State that the transferee is licensed to receive the by-
product material.
The inspector noted that for the planned May 14, 1991, shipment, the licensee was
unable to provide information, consistent with the above criteria, that the
transferee was authorized to receive the by-product material that the licensee was
planning to ship. The licensee did indicate that a representative (located on site)
of the transferee, had orally indicated that the transferee's license was valid and
did authorize receipt of the by-product material. However, the licensee was not
able to provide written confirmation of the oral verification (about 2 months after
the oral verification was made). As a result, the licensee suspended the shipment
pending verification as specified above. Subsequent inspector review indicated the
following:
The licensee was provided written confirmation on May 14, 1991, by a
letter dated September 7, 1990, that the expired license was in timely
renewal as provided in 10 CFR 30.37 (b) and was valid.
14
license. The license, dated August 31, 1990, was amendment 16. The
licensee had amendment 12.
Based on the above, the inspector concluded that the licensee did not have the
current license and did not" verify the transferee's licensee as specified above. In
addition, both the licensee's radwaste supervisor and QC inspector had signed-off
on the planned May 14, 1991, shipment. The licensee subsequently shipped the
coolant pump motor after performing the above verification.
The inspector's review of the licensee's records indicated that a similar shipment
had been made *on September 18, 1990. The shipment also was a reactor coolant
pump motor (Shipment No. 90-57) which contained about 20 microcuries of by-
product material and was shipped to the above discussed transferee.
The licen_see was unable to provide any documentation that the license verification
as specified in 10 CFR 30.41 ( c) was performed. This was identified as an
apparent violation (50-272/91-13-01; 50-311/91-13-01).
9.2
Radwaste Shipping - Hope Creek
During the inspection week, the inspector witnessed the preparation, loading, and
shipping of waste shipment no. 91-30. Fourteen (14), 55 gallon drums of
asphalt/waste were loaded on two (2) pallets and stacked inside a Chem Nuclear
shipping cask (CNS 14-215H-3). This cask loading area was outside the plant and
the shipment loading operation was performed by forklift and cherry picker.
Flanking this area is the Unit 2 turbine building which has been converted into
offices. Due to the waste drum dose rates, these offices were evacuated for each
cask loading operation. The loading of shipment no. 91-30 was smoothly
completed in approximately one (1) hour. Appropriate surveys, QC verifications,
and vehicle placarding were performed. Destination license and cask certificate of
compliance were verified. In general, this was a well executed shipment.
The unshielded loading operation described above resulted in 60 milli-person-rem.
To a great extent, the personnel exposures are a factor of the waste drum activity.
The subject shipment averaged roughly 800 mR/hr contact per waste drum.
Waste sludge and RWCU resin containing waste drums have historically measured
2 - 40 R/hr at contact. Due to external cask dose rate limitations, drums greater
- than 15 R/hr are retained in radwaste storage to decay. Waste drum shipments
between 8 and 11 R/hr resulted in approximately 200 milli-person-rem per
shipment. The original radwaste plant design did not include provisions for
shipment loading operations.
15
9.3
Shipment Scaling Factor Determinations
Hope Creek sends composite waste samples for off site laboratory radioisotope
analysis annually. The latest sample report was dated September 1990. The
samples represent RWCU resins, other system resins, oil, and waste sludge.
Waste sludge was used to represent general station Dry Active Waste (DAW).
The laboratory results were reviewed and entered into the appropriate RADMAN
program database for use in calculating waste shipment radionuclide information.
Each radwaste batch is routinely sampled and on site gamma scans performed as
input data for RADMAN calculations and as continuing verification of scaling
factor applicability and to detect radionuclide ratio changes. Apparently no QC
verification is performed after entering the laboratory data into RADMAN to
ensure correct RADMAN results are continued to be produced.
Salem has relatively few radwaste shipments and derives new scaling factors on a
biennial basis. Smear sample composites, primary clean up resin, and vendor
supplied liquid waste processing resin samples are analyzed as discussed above
including the lack of QC verification of RADMAN results after new scaling factors
are utilized. The ipspector verified laboratory scaling factor reports for smear
composite and primary clean up resins were current within two (2) years, but the
latest vendor resin sample analysis was dated June 2, 1988. The inspector
reviewed Salem shipping records and verified that no vendor resin shipments have
been shipped after January 1990. No discrepancies were noted.
9.4
Records
The following licensee radwaste shipping procedures were reviewed:
Hope Creek
Salem
"Radioactive Waste Sampling and Classification", HC.RP-TI.ZZ-0902(Q),
Rev. 2
"Dose Curie Conversion Calculations", HC.RP-TI.ZZ-0904(Q), Rev. 1
"Transfer of Radioactive Waste to SNGS", HC.RP-TI.ZZ-0905(Q), Rev.3
"Shipment of Radioactive Material Excluding Wastes For Burial", HC.RP-
TI.ZZ-0909(Q), Rev.3
"Operating Procedure For Asphalt Software", HC.RP-TI.ZZ-918(Q), Rev. 0
"Radioactive Waste Sampling and Classification", RP 902, Rev. 0
"Dose Curie Conversion Calculations", RP 904, Rev. 1
"Shipment of Radioactive Waste For Burial", RP 906, Rev. 0
"Shipment of Radioactive Material Excluding Wastes For Burial", RP 909,
Rev. 1
"Operating Procedure For Asphalt Software", RP 918, Rev. 0
16
In both the Hope Creek and Salem procedures entitled, "Shipment of Radioactive
Material Excluding Wastes For Burial", there was an incorrect definition of Type
B quantity which should be changed. No other discrepancies were noted.
The following shipping records were reviewed:
Hope Creek
Shipment
Activity (Ci) Volume (cu ft)
~
91-14
1.7 E-1
200
91-15
l.05E-1
423
91-16
2.8 E-6
0.7
Sample
91-17
5.2 E-8
0.7
Samples
91-18
l.3E-12
0.7
Samples
91-19
4.3 E-6
0.7
Samples
91-20
3.22E+2
120.3
Filter Media
91-21
3.22E+l
120.3
Filter Media
91-22
l.78E+2
120.3
Filter Media
91-23
6.04E+l
205.8
Resin
91-24
3.86E-1
2560
91-25
l.93E-2
960
Oil
91-26
5.12E+ 1
120.3
Filter Media
91-27
l.75E+2
120.3
Powdered Resin
91-28
1.46E+ 1
120.3
Filter Media
91-29
1.14E-1
2560
91-30
1.29E+ 1
105
Bitumen
Salem
Shipment
Activitv (Ci) Volume (cu ft)
Iyuf
91-10
1 E-5
1384
91-11
1 E-11
0.7
Samples
91-12
2.6E-2
225
91-13
3.lE-1
504
91-14
2.lE-2
1355
91-15
3.3E-i
2560
91-16
4.3E-4
2560
91-17
1.7E-3
26.2
91-18
2.51E-1
2560
91-19
1.4E-4
0.7
Samples
91-20
9 E-7
0.7
Samples
91-21
2.4E-6
288
Oil
91-22
1.3
588
DAV./
91-23
1.0
1015
17
Casks used/ Certificates of Compliance verified: CNS 14-215, CNS 8-120A
Destination licensee/ licenses verified: CNS Barnwell, SEG, Teledyne Isotopes, B
. & W. Fuel, Southwest Research, Westinghouse - Spartansburg, Westinghouse -
.Waltz Mill. Westinghouse - Cheswick was out of date as descnbed in Section 9.1
above. All the above shipping records (except Salem shipment 91-10 previously
described in Section 9.1) were complete and accurate.
10.0 - Interim Radwaste Storage
The inspectors reviewed with the licensee, plans for bn site storage of radwaste
beginning January 1, 1993 according to guidance contained in Generic Letter 81-
38, "Storage Of Low-Level Radioactive Wastes At Power Reactor Sites". A
feasibility study was completed by Sargent Lundy in March of 1990 recommending
the following five (5) alternatives for a design basis of five (5) years 9n site
radwaste storage for both Salem and Hope Creek facilities:
1. Build a new facility
2. Build an On Site Storage Container (OSSC) farm
3. Use the existing Hope Creek Unit 2 turbine building 137 foot elevation
4. Use the existing Hope Creek Unit 2 turbine building 77 foot elevation
5. Use the Hope Creek Unit 2 reactor building
A project manager has been appointed and the licensee indicated a Low Level
Radwaste Task Force would be formed to select a storage facility alternative and
facilitate a detailed design review. The licensee has made a start towards
developing a necessary on site storage facility.
11.0
Exit Meeting
The inspector met with licensee representatives denoted in section 1 of this report
on May 17, 1991. The inspector summarized the purpose, scope, and findings of
the inspection: