ML19320B571

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IE Insp Rept 50-346/79-34 on 791218-19.No Noncompliance Noted.Major Areas Inspected:Actions Taken in Response to IE Bulletin 79-19 Re Low Level Radwaste Packaging for Transport & Burial
ML19320B571
Person / Time
Site: Davis Besse 
Issue date: 06/13/1980
From: Fisher W, Greger L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19320B565 List:
References
50-346-79-34, IEB-79-19, NUDOCS 8007140471
Download: ML19320B571 (6)


See also: IR 05000346/1979034

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

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Report No. 50-346/79-3L

Docket No. 50-346

License No. NPF-3

Licensee: Toledo Edison Company

300 Madison Avenue

Toledo, OH 43652

Facility Name: Davis Besse Nuclear Power Station, Unit 1

Inspection At: Davis Besse Site, Oak Harbor, OH

Inspection Conducted: December 18-19, 1979

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Inspector

. R. G eger

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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 Summary

Inspection on December 18-19, 1979 (Report No. 50-346/79-34)

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." The inspection involved 14

inspector hours onsite by one NRC inspector.

Results: No items of noncompliance or deviations were identified.

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DETAILS

1.

Persons Contacted

  • B. Beyer, Assistant Superintendent

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  • D. Briden,. Chemist and Health Physicist
  • C. Daft, Quai?ty Assurance Manager

J. Greer, Quality Assurance Supervisor

  • J. Hickey, Trai t.ing Supervisor

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J. Hodgson, Ass..stant Engineer

T. Szydlowski, Station Services Foreman

  • L. Reyes, NRC Resident Inspector

The inspector also interviewed several other health physics and rad-

waste employees during the inspection.

  • Denotes those present at the exit interview.

2.

General

This inspection, which began at 12:15 p.m. on December 18, 1979, was

conducted to examine the licensee's processing, packaging, transfer,

and transport of low-level radioactive waste materials in response

to IE Bulletin 79-19.

3.

Regulations and License

The inspector verified that the licensee possessed current require-

ments of the commercial burial sites and a current copy of Nuclear

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Regulatory Commission regulations for the transfer, packaging, and

transport of radioactive material. Methods for maintaining these

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documents current had been established by the licensee.

The licensee had not procured an updated copy of the Department of

Transportation (DOT) regulations at the time of this inspection.

Difficulties apparently had been ancountered with availability

of the documents from two government offices. The licensee has

since reported that an updated copy of the DOT regulations has

been received. This will be verified during a future inspection.

4.

Designation of Responsibilities

Toledo Edison Nuclear Quality Assurance Procedure QAP 5220 and

Davis Besse Administrative Procedure AD 1850.00 delineate re-

spensibilities for - 7 cessing, packaging, transfer, and transport

of radioactive mat-.lal.

Although the designations of these

responsibilities are relatively clear, some problems were evident

-in implementing these responsibilities, especially between Station

Services personnel and Chemistry and Health Physics personnel. This

matter was discussed at the exit interview.

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5.

Procedures and Checklists

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The inspector selectively reviewed the following procedures related

to the transfer, packaging, and transport of radioactive waste ma-

terial.

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QAP 5220

(Rev. 1)

Radwaste Management

AD 1850.00

(Rev. 0).

Radwaste Management

AD 1850.02

(Rev. 1)

Solid Radioactive Waste Processing

and Handling

HP 1607.01

(Rev. 3)

Shipping Radioactive Material

SP 1104.28

(Rev. 1)

Solid Radioactive Waste Disposal

No discrepancies from the procedure review and approval require-

ments specified in Section 6 of the Technical Specifications were

noted.

The following problems were noted regarding procedure coverage and

implementation.

(1) A procedure had not been written for shipment

of low-level radioactive waste in wooden boxes.

(2) Packaged Rad-

waste Information forms and Solid Waste Storage Inventory and Dis-

posal logs were not used consistently.

(3) Written instructions

were not available for packaging of filters.

(4) Informal hand-

written procedures were used in place of formally approved proce-

dures which were readily available. These matters were discussed

at the exit interview.

Item 2 above is considered an unresolved

item which will be reviewed further during a future inspection.

6.

Training

The inspector reviewed the training program for personnel involved

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

material.

A revised training program for personnel involved in the processing

of low-level radioactive waste (i.e., operators and station services

personnel) was expected to be implemented by the end of January, 1980.

This training effort, which is under the purview of the Training

Department, will include use of formal qualification records to

document equipment knowledge and proficiency levels.

Instruction in regulatory and procedural requirements applicable to

the transfer, packaging, and transport of radioactive materials is

conducted by the Chemistry and Health Physics Section. This training,

last conducted in the latter part of 1978, was expected to be updated

and conducted again by the end of March 1980.

These items will be reviewed further during a future inspection.

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7.

Audits

The inspector reviewed the licensee's audit activities regarding

low-level radioactive waste transfer, packaging, and transport

activities. Conduct of the radwaste management audit is speci-

fied in QAP 5220. Although no audit frequency is specified in

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QAP 5220, an annual frequency was recently added to the audit

schedule. The two most recent audits of radwaste activities were

conducted in June'1978 and October 1979. One item remains out-

standing from the June 1978 audit. This item, related to main-

tenance of training and qualification records, was scheduled for

completion by January 31, 1980. According to licensee QA per-

sonnel, low-level radioactive waste transfer, packaging, and

transport activities will be included in future radwaste manage-

ment audits.

The October 1979 audit was conducted in response to IE Bulletin 79-19.

The audit included an examination of Items 1-6 of IE Bulletin 79-19,

except that in the area of procedures (Item 4) the audit examined

the administrative review and approval methods for new and revised

procedures but did not review procedure coverage or implementation.

This item was discussed at the exit interview. The licensee agreed

to perform additional audit activities in this area. This item will

be reviewed further during a future inspection.

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Administration of the audits was satisfactory regarding audit plans,

reports, corrective actions, and qualifications of personnel.

8.

Waste Packaging Systems

The licensee's installed radwaste solidification system (UF) has

never been used for radwaste processing, due to operational prob-

lems. A contractor provides onsite solidification services (UF).

The radwaste is solidified in 300 cubic foot liners, (coated for

corrosion resistance), which are also used as temporary storage

tanks. The liners and solidification equipment'are located in

the refueling building track alley. Normally, approximately two

to three liners are processed per month. Due to burial site re-

strictions on receipt of free liquid, little radwaste was solidi-

fied during the last half of 1979. The licensee had resumed

solidification operations shortly before this inspection upon

clarification of the Barnwell, South Carolina burial site re-

_quirements allowing free liquid in quantities totaling less than

one percent by volume. Multiple liner drainings were being con-

ducted to verify compliance with this requirement.

In addition'to the solidified evaporatoe bottoms, dry wastes (DAW),

both compactible and noncompactible, and filters have been shipped

offsite as radioactive waste.

It has not been necessary to ship

-radioactive resins from the site yet. Two problems were noted

regarding radioactive waste shipments:

(1; although DAW has been

packaged in wooden boxes (4 ft. x 4 ft. x 7 ft.) in addition to

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55-gallon drums, the licensee had no procedure defining design

specifications and usage restrictions for the wooden boxes; (2)

Seal injection filters had been shipped in lead-lined 55-gallon

drums as LSA material although evaluations were not available'to

verify that the radioactive material was properly classified as

LSA. This latter item is considered unresolved pending completion

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and review of evaluations to determine the proper shipping classi-

fication of these filters.

All radioactive waste shipments to date have been classified as LSA

or greater than Type A quantities. These shipments were made in ap-

propriate packages for their classifications. Shipment records

required by 10 CFR 71.62 are maintained.

9.

Examination of Package

The inspector examined two 300 cubic foot liners containing UF solidi-

fled evaporator concentrates. The waste matrix was solid (no free

liquid) when tested at the top of each liner by the inspector. The

liners were not equipped with drain plugs; a vacuum draining system

was installed. The vacuum drain was o.perated in the presence of the

inspector; no significant free liquid was extracted from the solidi-

fied liner checked.

A 55-gallon drum (B228-79) containing compacted trash awaiting ship-

ment was selected by the inspector and examined for proper contents.

The drum top was removed and the drum tipped to cLeck for the presence

of free liquid. No liquid was observed; the drum (ontents were as

described in the licensee's records.

10. Unresolved Items

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable items, items of

noncompliance, or deviations. Unresolved items disclosed during the

inspection are discussed in Paragraphs 5 and 8.

11.

Exit Interview

The inspector met with licensee representatives (denoted in Para-

graph 1) at the conclusion of the inspection on Decembcr 19, 1979.

The inspector summarized the scope and findings of the inspection.

In response to certain items discussed by the inspector, the li-

censee:

a.

Stated that measures would be taken to ensure that personnel

were aware of responsibility assignments related to the trans-

fer, packaging, and transport of low-level radioactive wastes.

(Paragraph 4)

b.

Stated that procedures related to the transfer, packaging, and

transport of low-level radioactive wastes would be reviewed and

necessary revisions made by March 1, 1980.

(Paragraph 5)

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Acknowledged the inspector's comments regarding the inability

c.

to locate Pac' aged Radwaste Information forms and Solid Waste

$torage Inventory and Disposal Logs.

(Paragraph 5)

d.

' Stated that training in regulatory and procedural requirements

applicable to the transfer, packaging, and transport of radio-

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active waste would be completed by the end of March, 1980.

(Paragraph 6)

e.

Stated that an audit of the acceptability of procedure cover-

age and adherence for the transfer,' packaging, and transport

of radioactive waste would be completed within 45 days after

approval of the revised procedures.

(Paragraph 7)

f.

Acknowledged the inspector's comments regarding evaluation of

the proper shipping classification for seal injection filters.

(Paragraph 8)

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