ML19309B774
| ML19309B774 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/31/1980 |
| From: | Fisher W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19309B767 | List: |
| References | |
| 50-010-79-23, 50-10-79-23, 50-237-79-27, 50-249-79-25, NUDOCS 8004070166 | |
| Download: ML19309B774 (7) | |
See also: IR 05000010/1979023
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U.S. NUCLEAR REGULATORY' COMMISSION
'0FFICE OF INSPECTION AND' ENFORCEMENT.
REGION III
Report No.'50-010/79-23;-
50-237/79-27; 50-249/79-25
- Docket No. 50-10; 50-237; 50-249
Licensee: Commonwealth Edison Company
P.O. Box 767
Chicago, IL 60690
Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3
Inspection At: Dresden Site, Morris, IL
Inspection Conducted: October 9 and November 28, 1979
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Inspector
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R.
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Approved By:
W. L. Fis ier, Chief.
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Fuel Facility Projects and
' Radiation Support Section
Inspection Summary
Inspection on October 9 and November 28, 1979 (Report No. 50-10/79-23;
50-237/79-27; 50-249/79-25)
Areas Inspected: Nonroutine, announced inspection of licensee actions
taken in response to IE Bulletin 79-19 " Packaging of Low Level Radio-
active 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,
So'uth Carolina. The inspection involved 14 inspector-hours onsite by
one NRC inspector.
'Results: Of the ten areas inspected, no items of noncompliance or de-
viations were found in nine areas. One apparent item of noncompliance
was found in the remaining area (deficiency - failure to follow proced-
ures Paragraph 5).
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DETAILS
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Persons Contacted.
- D. Adam, Radwaste Engineer
A. - Checca , ~ Training Supervisor
D. Farrar, Technical Staff Supervisor
- T. Gillman, Health Physicist
D. Howard, Senior Engineer (CECO)-
D. Sharper, Radwaste Foreman
- B. Stephenson, Plant Superintendent
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R. Stobert, Q.A. Manager
-The inspector also contacted several other licensee employees, in-
cluding members of the engineering and technical staffs.
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- Denotes those participating in 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 Health and Environmental Control were imple-
mented before resumption of radwaste shipments to Barnwell, South
Carolina.
An Order from the South Carolina Department of Health and Environ-
mental Control, dated October 12, 1979, prohibited further shipment
of radioactive waste to South Carolina from Commonwealth Edison
Company until certain corrective actions concerning packaging of
the waste materials were completed.
In a meeting between NRC
(Region III), South Carolina Bureau of Radiological Health, and
Commonwealth Edison Company personnel in' Columbia, South Carolina
on November 2, 1979, Region III agreed to review the first rad-
waste shipment from each Commonwealth Edison Company plant to
Barnwell, South Carolina following rescission of the shipping ban.
An Order rescinding the October 3,.1979, Order was issued on
November 9, 1979.
3.
Regulations and Licenses
The inspector verified that the licensee possessed current re-
quirements of the commercial burial sites and current copies of
the Department of Transportation and Nuclear Regulatory Commission
regulations for the transfer, packaging, and transport of radio-
active material. Methods for maintaining these documents current
had been established by'the licensee.
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4.
Designation of Responsibilities
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Procedure QP13-52 from the Commonwealth Edison Company Quality
. Assurance Manual delineates 1 responsibilities, by general job des--
cription, for the transfer, packaging,. and transport of radio-
active material. Although the licensee does not, in all cases,
correlate the general job descriptions to job titles specific to
.the;Dresden site, no problems were noted regarding implementation
of.the transfer, packaging, and transport responsibilities.
5.
Procedures and Checklists
The inspector 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
DRP 1520-1 (Rev. 2)
Offsite Shipment of
Radioactive Material
DRP 1520-2 (Rev. 3)
Curie Content of Radioactive
Shipments (Common Containers)
DRP 1520-3 (Rev. 2)
Curie Content of Radioactive
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Shipments (Nonroutine Containers)
DRP 1520-4 (Rev. 1)
Shipment of Wooden DAW Boxes as
Radioactive LSA
DRP 1520-6 (Rev. 0)
Surveying Radioactive Shipments
-DRP 1520-7 (Rev. 0)
Operation of Stock System
Labeling Station
DOP 2000-22 (Rev. 1)
Radwaste Compactor Operation
DOP 2000-31 (Rev. 0)
Solid Radioactive Material
System
DOP 2000-39 (Rev. 4)-
Loading of Radioactive Waste
Shipments
DOP 2000-40 (Rev. 3)~
Inspection of Radioactive Waste
Shipments
No discrepancies from the procedure review and approval format
specified in Section 6 of the Technical Specifications were noted.
The licensee was in the process of reviewing and revising, as
necessary, those radiation protection and operating procedures
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' relating.to the processing, packaging, transfer, and transportation =
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of radioactive material. As specified.in the September 21, 1979,
'- response to IE Bulletin 79-19, the' licensee expects to complete the
' review of all applicable ~ procedures by January 1, 1980.
To date,.the licensee has identified needed revisions to DRP 1520-1
(Offsite Shipment of Radioactive Material) and DRP 1520-4 (Shipment
of Wooden DAW Boxes as' Radioactive LSA). Additional needed changes
to DRP 1520-l', identified by the inspector, include:
exclusive use:
instructions, carrier' identification, package identification, and
vehicle contamination' control clarification.
The licensee possessed vendor procedures for handling (inspection,
' loading, closing) the specific cask types in use.
According to
licensee ~ personnel, cask closure devices will receive increased
attention to preclude repetition of past problems'with loose lid
. bolts / nuts upon arrival at the -burial site.
'One item of. noncompliance was identified for failure to follow
approved procedures in that the' Radioactive Material Shipment-
Record (RSR) has not been utilized as required by Section F.2 of
DRP 1520-1 for the radwaste shipments made between January 1,
1979, and November 28,.1979.
According to licensee personnel,
~ forms provided by the' radwaste contractor have been used in lieu
of the RSR contained-in Appendix I of DRP 1520-1. The substitute
forms contain the basic information required for radioactive mat-
erial shipments but do not contain all of the information in the
RSR from Appendix I of DRP 1520-1.
This area will be reviewed further during a future inspection in
order to examine the results of the operating procedure review and
to review the revised procedures.
6.
Training
The inspectors reviewed' the training programs for personnel involved
in the treatment, transfer, packaging, and. transport of radioactive
waste materials. Although training programs are not presently well
developed in.these areas, limited training has been provided to
radiation protection and applicable management personnel regarding
1 regulatory, licensee, and. procedural shipping requirements.
Initial
training on the proper operation of radioactive waste systems is
given to operations personnel. No retraining program has been
established in either area.
.As specified in the September 21, 1979 response to IE Bulletin 79-19, the'11censee is presently engaged in review and revision
of' the training programs for personnel involved in the treatment,
transfer, packaging, and transport of radioactive materials.
This training effort is' scheduled for completion by early 1980.
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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.
17.
Audits'-
The' inspectors _ reviewed the licensee's audit activities regarding
low-level radioactive waste transfer, packaging, and transport
activities. These areas are audited approximately 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 conducted by an offsite audit team on
-September 18-19, 1979. The audit included an examination of Items
1-6 of IE Bulletin'79-19. Three items remained open from the
September audit: the lack of current copies of waste burial licen-
ses, the lack of a retraining program for regulatory requirements
regarding low-level-radioactive waste transfer, packaging, and
transport, and the lack of a retraining program for waste solidi-
fication system operators. The first item had been corrected as
noted ~in Section 3 of this report. As noted in Section 6 of this
report, the remaining two items will be reviewed further during a
future inspection.
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8.
Waste Packaging Systems and Procedures
The inspector examined the licensee's waste packaging systems and
equipment. A Stock Equipment Company cement solidification system
was recently installed and is operational. The system, which has
not experienced significant problems to date, utilizes 55 gallon
drums with fill plugs rather than removable tops. Following addi-
tion of programmable amounts of cement and radwaste (resins, filter
sludge, evaporator concentrates), the drums are tumbled to accom-
plish mixing. A second fill and tumble sequence is normally fol-
lowed to promote consistent mixing. Although not required by pro-
cedure, drums are selectively inspected for mixture consistency and
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setup, especially immediately after changing feed material or mixing
proportions. The inspector discussed the importance of obtaining a
liquid-free final product. Results of the inspector's examination
of a cement-solidified drum is reported in Section 9 of this report.
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A DOW Solidification Process system is under construction for use
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in conjunction with the chemical cleaning of Unit 1.
Plans for
using this system after completion of the chemical cleaning opera-
tion have not been finalized.
Filters are normally packaged in 55 gallon drums which are pre-
loaded and topped with dry cement.
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L Compactible dry active: wastes are packaged in 55-gallon drums,
using a. conventional compactor. A'recently acquired compactor
allows about twice-the previous operating pressure.
Spent-resins'are routinely analyzed for strontiums and transuranics
-by a contract laboratory. These results.are used with the licen-
see's. isotopic analyses of radwaste to determine the nuclide and
-curie content of pacxaged waste.
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Examination of Package.
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LA 55 gallon drum containing cement-so1idified-evaporator bottoms
was selected by the inspector and examined for proper contents.
The top was opened and two holes made in the side of the drum near
the bottom. No free liquid was present at any of the locations
examined. The cement mixture had set up in a solid matrix. No
discrepancies were identified.
10.
Radioactive Waste Shipment
' The inspector examined a radwaste shipment (RSR 215-22409) made
during the inspection. Radiation levels associated with the loaded
shipment were independently verified by the inspector, who also re-
viewed and selectively verified the procedures and checklists assoc-
iated with the shipment.
The shipment consisted of 55 gallon drums (seven) containing cement-
solidified evaporator concentrates. The drums were loaded into an
HN600 cask which was used to provide shielding but which was not re-
quired to. meet " packaging": requirements. Total activity was approx-
imately 1.5 curies with a maximum of less than 250 millicuries per
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drum (Transport Groups III and IV). All external radiation levels
were within regulatory requirements; no discrepancies were identified
with the shipment.
The shipment departed the site for transport to a commercial burial
site or. November 28, 1979.
11.
Shipping Discrepancies
The inspector reviewed licensee records regarding a radwaste ship-
ment (RSR 215-22330) in response to a discrepancy identified by
personnel-from the State of South-Carolina Bureau of Radiological
Health at the Barnwell, South Carolina burial site.
No NRC enforcement action is warranted, as the discrepancy was
associated with a cask which was not used as a " package." The cask
was used to provide shielding to reduce vehicle exposure rates to
within' DOT limits; 55 gallon drums within the casks met the applic-
able " packaging" requirements.
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>The inspector also reviewed _ licensee records regarding a radwaste
. shipment (RSR 215-258632) which had been discovered to contain two
discrepant: packages upon arrival at the burial; site. The shipment
contained six wooden. boxes and 26 steel drums of LSA material. Two
of the wooden boxes had separated slightly at one or more' seams,
allowing several_ gallons.of contaminated gravel and dirt to leak
onto the-trailer floor. The inspector's review revealed that al-
though the licensee's procedures had been followed for the shipment,-
the procedures for wooden box usage did not' address construction
specifications for the boxes, weight limitations for the contents,
banding strength requirements, or the use of box liners.
In addi-
tion, banding was specified for only two of the three possible
directions. The seam separations on both boxes occurred at un-
banded seams. These-items were discussed at the exit interview.
The licensee has halted usage of LSA wooden. boxes for radwaste
packaging pending a thorough evaluation of such usage.
The Department of Transportation has initiated enforcement actions
regarding shipment RSR 215-258632.
12.
Exit Interview
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The inspector discussed the results of this inspection with licensee
representatives (denoted in Paragraph 1) by telephone on January 17,
-1980.
The inspector summarized the scope and findings of the in-
spection.
In response to certain items discussed by the inspector, the
licensee:
a.
Stated that procedural changes identified during licensee
and NRC reviews would be effected.
(Taragraph 5)
b.
Stated that a revised training program for the processing,
packaging, transfer, and transport of radioactive materials
would-be developed by January 18, 1980, and that the program
would be implemented by March 31, 1980. The training review
will include radwaste operate
'.aining/ retraining considera-
tions.
(Paragraph 6)
c.
Stated that methods for preventing loosening of cask lid bolts /
nuts during transportation were being pursued.
(Paragraph 5)
d.
Stated that there would be no further shipment of radioactive
waste in wooden LSA containers until a review of such shipment
methods was completed and the-present procedure for such ship-
ments was revised.
(Paragraph 11)
e.
Acknowledged the inspector's comments regarding the need for
ensuring solidification of radwaste.
(Paragraph 8)
f.
Acknowledged the inspector's comments regarding the noncom-
pliance item.
(Paragraph 5)
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