ML19294B271
| ML19294B271 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/07/1980 |
| From: | Nimitz R, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19294B267 | List: |
| References | |
| 50-293-79-19, NUDOCS 8002280119 | |
| Download: ML19294B271 (10) | |
See also: IR 05000293/1979019
Text
.
.
,'l
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Region I
Report No. 50-293/79- 19
Docket No. 50-293
License No. DPR-35
Priority
--
Category
C
__
Licensee:
Boston Edison Company
800 Boylston Street
Boston, Massachusetts
Facility Name:
Pilgrim Nuclear Power Station, Unit 1
Inspection at:
Plymouth, Massachusetts
Inspection conducted: November 27-29, 1979
Inspectors:
l'
\\
3 k BD
R. L. Nimitz, Radiat40n 5pecialist
date signed
~
'
date signed
date signed
Approved by: 2SLdNLA, M
//q/pn
J.P.StoffChief,RadiationSupport
' 'dd t'e"s i g n ed
Section,F/&MSBranch
Inspection Summary:
Inspection on November 27-29,1979 (Report No. 50-293/79-19)
Areas Inspected:
Special, unannounced inspection by one regional based inspector
of the actions taken by the licensee in response to IE Bulletin No. 79-19,
" Packaging of Lo.i-Level Radioactive Waste for Transport and Burial", including:
audits; document control; training; radioactive waste management organization;
procedures; shipment review; and plant tours.
The inspection involved 19
inspector-hours on site by one regional based inspector.
Results: Of the seven areas inspected, no items of noncompliance were observed.
Region I Form 12
(Rev. April 77)
80022 80 l ld
.
.
DETAILS
1.
Persons Contacted
P. F. Giardiello, Senior Compliance Engineer
- M. G. Hensch, Chief Radiological Engineer
R. Kuhn, Senior Alara Engineer
- R. Machon, Assistant Station Manager
- C. J. Mathis, Methods, Training and Compliance Group Leader
P. J. McGuire, Station Manager
- V. Stagliola, Senior Waste Management Engineer
- A. Trudeau, Senior Health Physics Engineer
- denotes those persons present at the exit interview on November 29,
1979.
The inspector also interviewed several other licensee employees,
including members of the health physics (HP) staff, reactor operations
and maintenance personnel.
Additionally, the inspector met with licensee QA auditors on November
29, 1979.
The meetirg, held to discuss Radioactive Waste Handling
and Shipping Audits, is addressed in Paragraph 2 and included the
following attendees:
J. B. Bellefeuille, QA Engineer
R. J. Kennedy, Senior QA Engineer
R. M. Titcomb, Senior QA Engineer
2.
Audits
The inspector noted through discussions with licensee representatives
that the licensee has established and implemented a quality assurance
program in accord with 10 CFR 71.51, " Establishment and maintenance of
a quality assurance program".
The quality assurance program submitted
pursuant to the above shall satisfy each of the applicable criteria
specified in 10 CFR 71 Appendix E, " Quality Assurance Criteria for
Shipping Packages for Radioactive Material," as required by 10 CFR 71.51(a).
The inspector reviewed licensee Quality Assurance Audit No. 79-13,
Licensed Shipping Casks, dated May 1, 1979 and No. 79-35, Radioactive
Materials Shipping, Calibration of Health Physics Measuring and Test
Equipment, dated November 1, 1979, with respect to Appendix E criteria.
.
.
3
Additionally, the inspector reviewed the 11censee's audit actions
taken with respect to IE Bulletin 79-19, " Packaging of Low-Level
Radioactive Waste for Transport and Burial."
The audit review included audit findings, auditor meetings with plant
management, plant management response to audit findings, audit re-
commendations and auditor follow-up to deficiencies and action items.
The inspector noted the reviewed audits to include the above items.
The audits also appeared to meet the requirements of licensee Quality
Assurance Manual Volume II, " Operation of Nuclear Power Plants",
section 18.4 " Reporting of Audit Findings."
The inspector met with licensee QA auditors (denoted in Paragraph 1)
and discussed the purpose and scope of audits in the areas of radio-
active waste packaging, handling and shipping.
The inspector also
discussed the audit findings with the auditors and indicated the
audits appeared to address the programatic areas adequately.
The
inspector noted and indicated that several audit areas appeared to
lack sufficient audit review to ensure the licensee was meeting the
applicable requirements or regulations.
The areas included:
meeting
burial site requirements with respect to free standing water, limits
on transuranics shipped to burial sites and personnel training.
The inspector discussed the above areas with licensee QA licensee
representatives and expressed concern with same.
The licensee representa-
tive indicated that for those specialized areas, the auditors normally
will request that a special audit be made to address those areas not
within the scope of the auditors background or training.
The inspector
noted the licensee auditors have planned to contract for audits in the
area of training of personnel in radioactive waste handling, packaging
and shipping.
The inspector indicated the above audit areas will be
reviewed at a subsequent inspection (293/79-19-01).
No items of noncompliance were observed in this area.
3.
Document Control
10 CFR 71 Appendix E, " Quality Assurance Criteria for Shipping Packages
for Radioactive Material", requires in Criteria 6, " Document Control"
that measures shall be established to control the issuance of documents,
such as instructions, procedures and drawings, including changes
thereto, which prescribe all activities affecting quality.
These
measures also shall assure that the documents are distributed to and
used at the location where the prescribed activity is performed.
.
4
The inspector reviewed document control and distribution for the following
documents:
10 CFR 20, " Standards for Protection Against Radiation"
--
10 CFR 71, " Packaging of Radioactive Material for Transport and
--
Transportation of Radioactive Material Under Certain Conditions"
40 CFR Parts 100 to 199, " Transportation"
--
South Carolina Radioactive Material License No. 097
--
Barnwell Site Disposal Criteria
--
--
Radioactive Waste Procedures
Applicable Package NRC Certificates of Compliance
--
a.
Use of Latest Revision Documents
The document review indicated the licensee maintains a subscription
service for document maintenance of:
10 CFR 20, 10 CFR 71, 39 CFR,
and 49 CFR.
The review also indicated the licensee had on-hand the
current amended South Carolina Radioactive Material License No. 97,
Amendment No. 26, current Barnwell Site criteria and applicable
package certificates of compliance.
No items of noncompliance were observed in this area.
b.
Document Distribution
The inspector reviewed the distribution and use of radioactive waste
handling procedures including those used by operating personnel.
During a tour of the Rad Waste Control Room, the inspector noted,
through discussions with operating personnel in the area, that a B
Clean Waste Tank was being processed.
The inspector discussed the
processing operation with the operating personnel and questioned
same as to availability and use of process operating procedures for
this particular operation.
The operating personnel indicated controlled
copies of the procedures were on file in the Rad Waste Control Room
and attempted to locate same for the inspectors review.
The inspector
noted the operating personnel were unable to locate the applicable
procedures and indicated the procedures had been on file.
The
inspector noted through further discussions with the operating
personnel that the procedures were referenced during rad waste
operations.
The discussions also indicated that Procedure No.
2.2.72, Revision 4, " Clean Radwaste System", dated December 21,
1977, is used for guidance in processing clean waste and was not in
place.
.
.
5
The inspector discussed the lack of operating procedures at the Rad
Waste Control Panel with licensee operations representatives.
The
licensee representatives indicated that procedures had been removed
for updating and also indicated this item, use of rad waste procedures
at the Rad Waste Control Panel, had been addressed in an Operation
Review Committee (ORC) meeting on November 23, 1979.
The inspector reviewed the draft minutes of ORC Meeting No. 79-60
and noted the above item to be addressed as ORC Follow-up Item No.
79-60-01
Iicensee representatives indicated controlled copies of
tha applicable operating procedures would be placed in the Rad Waste
ontrol Room (293/79-19-02).
.
No items of noncompliance were observed in this area.
4.
Training
IE Bulletin 79-19, " Packaging of Low Level Waste for Transport and Burial,"
dated August 10, 1979, requires action be taken by the licensee to provide
training and periodic retraining for those personnel involved in the
transfer, packaging and transport of radioactive material.
The bulletin
also requires training and periodic retraining be given to those personnel
who operate the processes which generate radioactive waste including
training in:
waste minimization and waste processing to assure waste is
processed into acceptable chemical and physical form for transfer shipment,
and burial.
The inspector reviewed the licensee's bulletin response dated October 2,
1979 with respect to the above.
The bulletin response review indicated
that, with respect to Item 6, the licensee will develop and implement by
October 1, 1980, a formal training and periodic retraining program for
those personnel who operate the processes which generate radioactive
wastes.
Inspector discussion with licensee representatives indicated
that contractor audit findings of training, as discussed in paragraph 2,
will be incorporated into the formal program.
The inspector noted that
in the interim, on-the-job training is given.
Additionally, operators
currently " sign-off" having read new or revised procedures.
The licensee Radioactive Waste Management Group currently provides periodic
training and retraining to those personnel involved in the transfer,
packaging and transport of radioactive materials as indicated in licensee
response to Item No. 5 of IE Bulletin 79-19.
The inspector discussed the training provided as indicated in Item No. 5
response with licensee Radioactive Waste Management representatives.
.
.
6
The inspector discussions indicated that no formal program to provide
training and periodic retraining for those personnel involved in the
transfer, packaging and transport of radioactive material is in place.
The discussions also indicated that no method is in place to assure the
above personnel have an adequate understanding of the applicable regulatory
and procedural requirements regarding the above.
The licensee Waste Management Group representatives indicated that a
formal training program will be established and implemented by May 1,
1980.
The training program, according to licensee representatives, will
include the use of training procedures and qualification cards.
As above, the licensee will provide on-the-job training by senior per-
sonnel in the interim.
The inspector indicated the above training programs will be reviewed
during a subsequent inspection (293/79-19-03).
No items of noncompliance were observed in this area.
5.
Radioactive Waste Management Organization
The licensee has submitted Proposed Administrative Technical Specifi-
cation change No. 5, dated September 27, 1979 for modification of the
Pilgrim Station Organization.
The change would consist of restructuring
the organization delineated in Unit 1 Techncial Specification Appendix A,
Section 6 Figure 6.2.2 and would serve to restructure reporting requirements
and improve workload distribution as indicated in the licensee's proposed
change.
The inspector discussed the proposed restructuring with licensee repre-
sentatives and noted the proprosed organizational structure to be in
place with respect to radioactive waste management.
The inspector noted
the personnel designated in licensee IE Bulletin 79-19 response, as
responsible for the safe transfer, packaging and transport of low level
radioactive material, to be acting in that capa ity.
The inspector
discussions and organizational review indicateu the proposed structure
appears adequate to ensure safe transfer, packaging and transport of low
level radioactive material.
No items of noncompliance were observed in this area.
.
7
6.
Procedures
The inspector reviewed the following procedures to verify preparation
and/or revision in accordance with the requirements of Technical Specifi-
cation 6.8, " Procedures" and Pilgrim Nuclear Power Station (PNPS) Admin-
istrative Procedure 1.3.4, Rev. 20, " Procedures", dated May 22, 1979.
PNPS Procedure No. 6.9-160, Rev. 2, " Shipment of Radioactive Material,"
--
dated November 15, 1978.
PNPS Procedure No. 7.3.25, Rev. G, " Solid Radwaste Shipment Activity
--
Determination," dated February 27, 1978.
PNPS Procedure No. 2.2.72, Rev. 4, " Clean Radwaste System," dated
--
December 21, 1977.
PNPS Procedure No. 2.2.73, Rev. 4 , " Chemical Radwaste System Without
--
Concentration and Solidification," dated December 21, 1977.
No items of noncompliance were observed in this area.
7.
Shipment Review
The inspector reviewed the following radioactive waste shipments for
compliance with the requirements of 10 CFR 71, " Packaging of Radioactive
Material for Transport and Transportation of Radioactive Material under
Certain Conditions" and 49 CFR Parts 100 to 199, "Transporation." The
shipments had been identified as discrepant shipments during inspections
conducted at the Barnwell, South Carolina Disposal Site.
The inspector reviewed included:
radiation and contamination surveys
(both incoming and outgoing); curie determinations; certificate of compliance;
loading check off sheets and other documentation associated with the
shipment.
PNPS Radioactive Shipment Record (RSR) #79-41.
Shipment date April
--
10, 1979
PNPS Radioactive Shipment Record (RSR) #79-42.
Shipment date April
--
10, 1979
PNPS Radioactive Shipment Record (RSR) #79-64.
Shipment date June
--
12, 1979
.
.
8
The reviev indicated no documentation, as required by 10 CFR 71.62,
" Records," were available to indicate the packages had been loaded and
closed in accordance with written procedures as required by 10 CFR 71.54,
" Routine determinations".
Additionally, the inspector noted the licensee
to have made a shipment, RSR #79-42, in a package the licensee had not
previously registerad to use as required by 10 CFR 71.12(b)(1)(iii).
The inspector discussed the above findings with licensee representatives
and noted the abeve to have been addressed in licensee audits.
The
audits include QAD audit Nos. 79-13 and 79-35.
The inspector noted that, as a corrective measure, the licensee has
registered with the NRC to use the shipping package (BECo letter No.79-217 dated October 26,1979) and is currently revising and preparing
additional procedures to preclude recurrence.
The inspector indicated
the revised and newly prepared procedures addressing radioactive waste
packaging and shipping will be reviewed during a subsequent inspection
(293/79-19-04).
No items of noncompliance were observed in this area.
8.
Plant Tour
The inspector toured radioactive waste handling areas and reviewed radio-
active waste handling activities for conformance to the following:
10 CFR 71, " Packaging of Radioactive Material for Transport and
--
Transportation of Radioactive Material Under Certain Conditions."
49 CFR 100 to 199, " Transportation."
--
PNPS Procedure No. 6.9-160, Rev. 2, " Shipment of Radioactive Material,"
--
dated November 15, 1978.
a.
LSA Truck Loading
The inspector reviewed Low Specific Activity (LSA) waste loading on
November 28, 1979.
The inspector noted the loading, closure, marking, labeling and
package construction to meet the requirements of:
.
9
49 CFR 173.392, " Low Specific Activity Radioactive Material"
--
49 CFR 172.24, " Standard requirements for all packages"
--
The inspector reviewed an open LSA shipping container and noted same
to be a strong tight package which is closed and secured via metal
bonding after loading.
The inspector discussed the package and its
uses with licensee waste management representatives.
The inspector
discussions indicated the package is used within the activity limitations
specified in IE Circular No. 78-03, " Packaging Greater Than Type A
Quantities of Low Specific Activity Radioactive Material for Transport."
b.
Compactor Operation
The inspector reviewed compacted waste and waste preparing to be
compacted.
The inspector noted only paper and dry trash was being
compacted.
The compactor utilizes wax coated boxes as a container.
The waste
is compacted in plastic bags lining the boxes.
The wax coated boxes
are subsequently packed in LSA boxes (addressed above) for shipment.
The inspector had no further questions in this area.
c.
Resin and Filter Handling
The lice.see transfers radioactive waste to a waste burial contractor
authori_ed to received same in a license issued by an Agreement
State.
This transfer is permitted as specified in 10 CFR 30.41,
" Transfer of byproduct material."
The inspector reviewed the contractor's burial license conditicas
specifying material that may be received.
The inspector noted the
current Radioactive Material License, No. 097, Amendment No. 26, to
define "no detectable free standing liquids as 1% liquid by volume."
The inspector discussed the above burial site requirement with
licensee radioactive waste management representatives and noted the
following:
All powdex resin residue and diatomaceous earth utilized by the
--
licensee's flatbed filter operation is dried by heaters prior
to placement in package liners for shipment.
.
10
All spent resins for offset shipment are dewatered by a procedural
--
operation.
The inspector questioned licensee representatives as to how they
assure dewatered resins do not contain liquid in excess of burial
site limits.
The discussions indicated the licensee has identified
this problem and has contracted with a firm to construct liners that
have the capability to ensure proper drainage.
The inspector reviewed
the liner blueprints and noted liner design appeared to preclude
free standing water.
The inspector r.oted that, as of November 29, 1979, the licensee has
suspended all resin shipments until such time the re-designed liners
may be utilized.
The licensee was noted to have adequate spent
resin storage capacity to accomplish this.
The licensee indicated
the new liners should be in use by approximately April 1980 (293/79-19-05).
No items of noncompliance were observed in the above areas.
9.
Exit Interview
The inspector met with licer.ae representatives (denoted in Paragraph 1)
at the conclusion of the in: . .ction on November 29, 1979.
The inspector
summarized the purpose and s. ope of the inspection findings.
The licensee representatives indicated dewatered resin shipments will be
suspended until such time redsigned liners are available for use (Details
paragraph 8).