ML19262C399

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IE Insp Repts 50-254/79-26 & 50-265/79-23 on 791113-15.No Noncompliance Noted.Major Areas Inspected:Actions Taken in Response to IE Bulletin 79-19 & Verification That Identified Packaging Discrepancies Were Corrected
ML19262C399
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 12/21/1979
From: Fisher W, Greger L, Peck C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19262C395 List:
References
50-254-79-26, 50-265-79-23, NUDOCS 8002120147
Download: ML19262C399 (7)


See also: IR 05000254/1979026

Text

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMEhT

REGION III

Report Nos. 50-254/79-26 and 50-265/79-23

Docket Nos. 50-254 and 50-265

License Nos. DPR-29 and DPR-30

Licensee:

Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: Quad-Cities, Units 1 and 2

Inspection At:

Cordova, Illinois

Inspection Conducted: Nove be

3-15,1979

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Inspectors:

L. R. Greg

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. Peck

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Approved By:

W. L. Fisher, Chief

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Fuel Facility Projects and

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Radiation Support Section

Inspection Summsry

Inspection on November 13-15, 1979 (Report Nos. 50-254/79-26 and 50-265/79-23

Areas Inspected: Nonroutine, announced inspection of licensee actions

taken in response to IE Bulletin 79-19 " Packaging of Low-Level Radioactive

Waste for Transport and Burial" and, as agreed with the State of South

Carolina, verification that identified packaging discrepancies were

corrected before resumption of radwaste shipments to Barnwell, South

Carolina. The inspection involved forty inspector-hours onsite by two hTC

inspectors.

Results: No items of noncompliance or deviations were identified

1948

206

8002120147

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DETAILS

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1.

Persons Contacted

  • R. Bax, Assistant Superintendent, Maintenance
  • R. Flessner, Radiation Chemistry Supervisor

J. Forrest, Radwaste Supervisor

  • K. Graesser, Assistant Superintendent, Administrative
  • J. liielman, Quality Assurance
  • N. Kalivianakis, Station Superintendent
  • T. Kovach, Lead llealth Physicist
  • R. Petri, Radwaste Supervisor

P. Shafer, llealth Physicist

P. Skiermont, Training Supervisor

  • T. Tamlyn, Assistant Superintendent, Operations

The inspectors also interviewed several other health physics and

radwaste employees during the inspection.

  • Denotes those present at the exit interview. (N. Chrissotimos,

resident inspector, also attended the exit interview.)

2.

General

This inspection was conducted to examine the licensee's treatment,

packaging, transfer, and transport of radioactive waste materials in

response to IE Bulletin 79-19 and to verify that certain procedural

modifications instituted in response to issues raised by the South

Carolina Department of Ilealth and Environmental Control were corrected

before resumption of radwaste shipments to Barnwell, South Carolina.

An Order from the South Carolina Department of llealth and Environ-

mental Control, dated October 12, 1979, prohibited further shipment

of radioactive waste to South Carolina by Commonwealth Edison Company

until certain corrective actions concerning packaging of the waste

materials were completed.

In a meeting attended by NRC, South

Carolina Bureau of Radiological Health, and Commonwealth Edison

Company personnel in Columbia, South Carolina on November 2, 1979,

NRC Region III agreed to review the first radwaste shipment, from

each Commonwealth Edison Company plant, to Barnwell, South Carolina

following rescission of the shipping ban. An Order rescinding the

October 12, 1979, Order was issued on November 9, 1979.

3.

Regulations and License

The inspectors verified that the licensee possessed current require-

ments of the commercial burial sites and current copies of the Depart-

ment of Transportation and Nuclear Regulatory Commission regulations

1948 207

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for the transfer, packaging, and transport of radioactive material.

Methods for maintaining these documents current had been established

by the licensee.

4.

Designation of Responsibilities

Procedure QP 13-52 from the Commonwealth Edison Company Quality

Assurance Manual delineates responsibilities, by general job descrip-

tion, for the transfer, packaging, and transport of radioactive

material. Although the licensee does not, in all cases, correlate

the general job descriptions to job titles specific to the Quad-Cities

site, no problems were noted regarding implementation of the transfer,

packaging, and transport responsibilities.

5.

Procedures and Checklists

The inspectors selectively reviewed the following procedures related

to the transfer, packaging, and transport of radioactive waste

material.

QP 13-52 (Rev.2)

Preparation and Shipment of Radioactive

Material

QRP 100-2 (Rev.2)

Offsite Shipment of Radioactive Material

QRP 100-21 (Rev.3)

Calculation of Curie Content of Radio-

active Material

QRP 100-23 (Rev. 1)

Program for Maintaining Copies of...

Licenses

QRP 100-44 (Rev. 3)

Release of Radioactive Material Ship-

ments

QRP 100-50 (Rev. 1)

Radioactive Waste Transportation

QRP 100-S2 (Rev. 3)

Vehicle / Package Release Form

QRP 100-S26 (Rev. 1)

RCT Worksheet for Radwaste Shipments

QOP 2090-0 (Rev. 9)

Drum Operations

QOP 2090-2 (Rev. 4)

Drum Filling

QOP 2090-3 (Rev. 3)

Drum Mixing

QOP 2090-5 (Rev. 4)

Drum Capping

QOP 2090-7 (Rev. 1)

Drum Shipping

QOP 2090-9 (Rev. 1)

Manual Cement Feed to a 55 Gallon Drum

QOP 2090-10 (Rev. 4)

Loading Storage Line Drums into Top-

Loading Casks

QOP 2090-11 (Rev. 4)

Loading Overpack Drums into Top-Loading

Casks

QOP 2090-12 (Rev. 3)

Loading Dry Active Waste (DAW) Contain-

ers on Unshielded Trailers

QOP 2090-13 (Rev. 3)

Loading Storage Line Drums into Rear

Loading Casks

QOP 2090-S1 (Rev. 1)

QC Radioactive Waste Cask Shipment

Check Sheet

f948

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No discrepancies from the procedure review and approval format

'

specified in Section 6.2 of the Technical Specifications were noted.

The licensee had completed a review of the radiation protection

procedures relating to the transfer, packaging, and transportation

of radioactive material and had commenced a review of pertinent

operating procedures. As specified in the September 21, 1979, response

to IEB 79-19, the licensee expects to complete the review of all

applicable procedures by January 1, 1980.

The licensee has identified needed revisions and additional procedures

during the review. Additional needed revisions were identified by

the inspectors. The following procedures need implementation or re-

vision:

Operation of Compactor (Need procedure.)

Use of DAW Wooden Box (Need procedure.)

QP 13-52 (Revise regarding container seals.)

QRP 100-2 (Identify carrier, define package, provide exclusive use

instructions, and clarify use of vehicle contamination control in-

formation.)

The operating procedure review currently underway will include an

evaluation of the need for cask handling procedures specific to each

cask model. At present, the operating procedures group casks into

" top-loading" and " rear-loading" categories for procedural treatment,

but do not incorporate cask specific information such as torque re-

quirements.

This matter will be reviewed further during a future inspection in

order to examine the results of the operating procedure review and

to review revisions to procedures. The lack of a procedure for

compacting radioactive trash was identified by the licensee before

this inspection. An internal Action Item Request (AIR 4-79-22) had

been initiated by the licensee to correct this matter.

6.

Training

The inspectors reviewed the training programs for personnel involved

in the treatment, transfer, packaging, and transport of radioactive

waste materials. Although the training program is not presently

well developed in these areas, training documentation substantiated

that at least limited initial training is given to radiation protection

personnel regarding regulatory and license requirements and procedures.

No retraining program has been established.

Training on the proper operation of radioactive waste systems is

given to operations personnel.

Such training, although provided on

a continuing basis, appears to lack clear definition regarding con-

. tent and administration.

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As specified in the September 21, 1979, response to IEB 79-19, the

licensee is presently reviewing and revising the training programs

for personnel involved in the treatment, transfer, packaging, and

transport of radioactive waste materialr. This training effort is

expected to be completed by early 1980.

This matter will be reviewed further during a future inspection in

order to examine the results of the training reviews and changes

implemented by the licensee.

7.

Audits

The inspectors reviewed the licensee's audit activities regarding

low level radioactive waste transfer, packaging, and transport

activities. These areas are audited approximate'y annually accord-

ing to licensee personnel and audit records. Administration of the

audit function was satisfactory regarding audit plans, reports,

corrective actions, qualifications of personnel, etc.

A special audit was coaducted by an offsite audit team on

September 26-27, 1979. The audit included an examination of Items

1-6 of IEB 79-19.

One item remained open from the September audit:

lack of a retraining program in regulatory requirements regarding

low level radioactive waste transfer, packaging, and transport. As

noted in Section 8 of this report, this item will be reviewed further

during a future inspection.

8.

Waste Packaging Systems

The inspectors observed the operation of the installed cement solid-

ification system used to solidfy spent resin in 55 gallon drums.

The drums, containing fifty pounds of dry cement, are moved to a

filling station, where water and resin are added, then to a mixing

station for addition and mixing of cement, and finally to a capping

station where the mix is inspected and the drum is capped and closed.

Amounts of resin, water, and cement are standardized and specified

in operating procedures.

Inspection of the completed mix is visual;

radwaste operators use color and consistency to decide whether the

mix is acceptable and contains no free standing liquid. After

capping there is no opportunity to detect the presence of liquid.

The inspectors emphasized to licensee representatives during the

inspection and at the exit interview the importance of ensuring that

the drums do not contain free liquid.

A urea formaldehyde solidification process was used for a small

number of containers in the past; no further use is planned.

Installation of Dow Solidification Process equipment is in progress

(scheduled for operation in early 1980.) Replacement of the cement

process by the Dow Solidification Process will depend on the success

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of the new installation.

It is planned to keep the cement system

available for use at present.

Contaminated filters are packaged in 55 gallon drums or metal boxes,

depending on filter size. Drums are prepared by pouring a concrete

mix around a centered core. The boxes, used for larger filters, are

loaded with dry cement.

For compactible dry active waste (DAW), the licensee uses equipment

which compacts ano bands the waste into bales for packaging in

appropriate containers.

9.

Examination of Package

One of the drums of cement solidified resin in storage was opened

for examination by the inspectors. No liquid was present on top of

the solid mass. Six holes were then punched in the side of the drum

near the bottom, about ten inches from the bottom and about twenty

inches from the bottom. No water was present at any of the locations.

Probing into the mix disclosed unbound resin beads. These were

present in greater quantity near the bottom of the container. Unbound

beads are apparently typical according to licensee representatives,

who have photographs of a sectioned drum which show that loose resin

is present in the periphery of the mixture.

10.

Radioactive Waste Shipments

The inspectors examined two radwaste shipments (No. 948 and No. 949)

made during the inspection. Radiation levels associated with the

loaded shipments were verified by the inspectors, who also reviewed

and selectively verified the procedures and checklists associated

with the shipments.

Both shipments consisted of 55-gallon drums (seven) containing

cement solidified resins. The drums were loaded into HN600 casks,

which are certified to carry greater than Type A quantities of LSA

material.

Total activities in the casks were approximately 50

curies and 80 curies, respectively, of LSA material. All external

radiation levels were within regulatory requirements. A temporary

"see-through" enclosure was constructed to restrict access of un-

authorized persons to the cask on one of the shipments. This action

was necessitated by radiation levels in excess of 10 mR/hr at three

feet from the cask. No discrepancies were identified with either

shipment.

Both shipments departed the site for transport to a commercial

burial site on November 14, 1979.

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11.

South Carolina Sbipment Discrepancy Reports

The inspectors reviewed licensee records regarding two shipments

(RSR Nos. 875 and 876) in response to discrepancies identified by

personnel from the State of South Carolina Bureau of Radiological

Health at the Barnwell, South Carolina burial site.

No enforcement action was warranted in either case as the discrep-

ancies were associated with casks which were not used as " packages."

The casks were used to provide shielding to reduce vehicle radiation

dose rates to within DOT limits; 55-gallon drums within the casks met

the applicable " packaging" requirements.

Although not mentioned in these discrepancy reports, problems have

been encountered in the past with cask closure bolts / nuts being

loose upon arrival at the burial site even though licensee personnel

claim to have tightened them adequately before departure from their

site. This matter is being pursued by licensee personnel with the

cask supplier.

12.

Exit Interview

The inspectors met with licensee representatives (denoted in

Paragraph 1) at the conclusion of the inspection on November 15,

1979. The inspectors summarized the scope and findings of the

inspection.

In response to certain items discussed by the in-

spectors, the licensee:

Stated that procedural changes / additions identified during

a.

their reviews and the NRC inspectors' review would be effected.

(Paragraph 5)

b.

Acknowledged the inspectors' comments that the training program

for the transfer, packaging, and transport of radioactive waste

materials was weak and stated that a revised training program

would be finalized by January 18, 1980, and the program imple-

mented by March 31, 1980. The training review is to include

radwa te operator training / retraining. (Paragraph 6)

c.

Stated that methods for preventing loosening of cask lid bolts / nuts

during transportation were being pursued. (Paragraph 11)

d.

Acknowledged the inspectors' comments regarding the need for

ensuring solidification of radwaste. (Paragraph 8)

e.

Acknowledged the inspectors' comments regarding the cement

solidified 55 gallon drum that was examined by the inspectors.

(Paragraph 9)

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