ML20043A927

LER 89-030-01:on 890726,Tech Spec Violation Occurred Due to Shipment of Two Liners of Secondary Bead & Powdex Resin Mixture.On 891215,same Tech Spec Violation Occurred.Caused by Mgt Deficiency.Shipments suspended.W/900503 Ltr

ML20043A927
Person / Time
Site:	Catawba
Issue date:	05/03/1990
From:	Hartzell C, Owen T DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-030-01, LER-89-30-1, NUDOCS 9005230296
Download: ML20043A927 (8)

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May 3, 1990 Document Control Desk U. S. Nuc1 car Regulatory Commission ifashington, D. C. 20555

Subject:

Catawba Nuclear Station Docket No. 50-413 LER 413/89-30, Rov 1' Gentlemen:

Attached is Licensco Event Report 413/89-30, Rev 1 concerning

. TECHNICAL SPECIFICATION VIOLATION DUE TO SHIPMENT OF TWO LINERS 0F SECONDARY BEAD AND POWDEX RESIN MIXTURE IN VIOLATION OF.THE PROCESS CONTROL PROGRAM.

This event was considered to be'of no significance with respect to.the health and safety of the public.

Very truly yours, 7

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Tony E. Owen Station Manager heb\LER-NRC.TBO xc: Mr. S. D. Ebneter American Nuclear Insurers Regional Administrator, Region II c/o Dottle Sherman, ANI; Library U. S. Nuclear Regulhtor Comission. .The Exchange, Suite 245 101 Marietta Street, NW, Suite 2900 270 Farmington Avenue Atlanta,~GA 30323 Farmington, CT 06032 M & M Nuclear Consultants Mr. K. Jabbour 1221 Avenues of the Americas U. S. Nuclear Regulatory Commission Now York, NY 10020 Office of Nuclear Reactor Regulation Washington, D. C, ,20555 INPO Records Center Suite 1500 Mr. W. T.: Orders 1100 circle 75 Parkway NRC Resident Inspector

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" Technical Specification Violation Due To Shipment Of Two Liners Of Secondary 5ead And 1 Powdex Resin Mixture in Violatt on Of The l'roecss Control Procram i IVINT Daf t IS, Lt m NUMDt h (Si DEPORT DAf f (7) OTHim 9 ActLitttl INv0LvtD tel DDC d[Nu. alit mis 6 MON 9H DAY v4R vtan 58gy(Ab ~~

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• HONE Nuesta Anta c006 C.L. Ilartzell. Compliance Manager BO3 i i 1 1 1i 31 6 6l5 831 COMPLif t DNt LINE FDA B ACH COMPONENT F AILumt OtscaistD IN THIS REPom? (131 Coust sytttv Cour0NtNT T[g$C "3o$,'n' s CAust syst tM CovPONENT "$'lC g ,Tpa sL l i I I I I I I I I I I I I I l 1 1 l 1 l i 1 i l i I 1 SUPPLEMENT AL,mtPORT t xPicitD Od! VONTH Dav VIAR SU'0 Vi S560 N

~~'] v e s ters.,.w.. tnotcroc suowssion carts J NO l l l A.we Ac i m ., M i m <.. . . . .,y.. ., ,, ...,,. . ,,,..,. .. ,. .., n e i On July 26, 1989, with Units 1 and 2 in Mode 1, Power Operation, two carbon steel liners containing a mixture of powdex and bead resins were shipped to the Low Level Waste Repository in Barnwell, S.C. Verbal Vendor approval of this shipment had been obtained. On December 7, 1989, Duke Power Company (DPC)

, Nuclear Chemistry issued a letter to CNSI Engineering discussing the possibility l of mixing of bead and powdex resins. This letter was copied to the CNS

- Chemistry Scientist who realized that these types of resin loadings had previously been shipped from CNS. CNSI Operations, Engineering and DPC Nuclear Chemistry were contacted. On December 15, 1989, it was determined that a l

Technical Specification violation had occurred due to the shipment of two mixed o media resin liners in violation of the Process Control Program. ~ Further shipments of mixed media secondary resin at CNS have been suspended until proper testing on dowatering effectiveness of mixed media resins haa been determined.

This incident is attributed to a Management Deficiency. Subsequent tests on conservatively similar loaded mixed resin liners have shown that the liners shipped on July 26, and buried at the Low Level Waste Repository at Barnwell, S.C., were adequately dewatered for burial.

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BACKGROUND i '

$ The Condensate [EIIS:SD) (CM) System takes Condensate from the Main Turbine Condenser Hotwell and purifies it to meet water chemistry specifications in the ,

t Condensate Polisher Domineralizers [EIIS:KD] (CPD) and after reheating delivers the Condensate to the Main Feedwater [EIIS:SJ)"(CF) System for delivery to the Steam Generators [EIIS:HX).(S/Gs). The CPD's are used to remove ionic and ,

particulate contaminants from the condensate to minimize corrosion products

• which could affect Unit performance. The CPD's utilize a powdered. resin form '

and a precoat filter media. When a CPD cell reaches the end of its life the spent powder resins and filter aids are backwashed and drained-to the CPD l Backwash Tank. The spent resins are sampled and isotopically analyzed prior to  ;

discharge to insure the limits imposed by the State of S.C. and the NRC are not  ;

exceeded. This spent resin is not normally contaminated and is discharged via the Conventional Waste [EIIS:WH] (WC) System. If the limits are exceeded the spent resin is transferred to carbon steel liners for burial as Class A unstable waste at the Barnwell Low Level Waste Repository.

The S/G Blowdown [EIIS:WI] (BB) System assists jn maintaining-proper S/G shell side water chemistry by removing non volatile materials that would otherwise -

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concentrate in the shell side of the S/G's. This ic accomplished by bleeding saturatad condensate from locations near the bottom of the S/G's to the BB tank. The BB tank receives the saturated bleed from the S/G's where part of the saturated condensate expands to steam and is delivered to the CF heaters for, l heat recovery. The remaining BB condensate normally flows through the BB Heat Exchangers, Profilters and demineralizers to the Condenser Hotwell. The BB domineralizers use a bead type resin to remove ionic and particulate

? contaminants. The spent resina from the BB domineralizers can be discharged to L the WC System if not contaminated or to a liner for burial at e Low Level Waste Repository if contaminated. i

, The Duke Power Company (DPC) Corporate Process Control Program (PCP) establishes *

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b "a set of requirements that shall be met.at all Nuclear Stations to insure all solidification and dewatering activities are conducted in a ranner and produce a  ;

final product that complies with all applicable Federal and State regulations  ;

L and licensed burial site criteria". . Station specific procedures have been lr developed to implement the requirements'of the PCP, The station specific procedures incorporate the chem-Nuclear Systems Incorporated (CNSI) procedures for dowatering carbon steel liners. CNSI is contracted by DPC to provide l

dewatering services and provide the liners used for burial at the Low Level

Waste Repository in.Barnwell, S.C. The' liners are equipped with dewatering l laterals designed for dewatering specific resin forms. The'powdex resin liners i

are equipped with three to four drain laterals located at different elevations in the liner, whereas the bead resin liners are equipped with one dewatering lateral located at the bottom of the liner. CNSI also provides specific-procedures for fill and dewatering of powdex and bead resin which are Enclosures e

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4.5 and 4.6, respectively, of Chemistry Procedure OP/0/B/6500/09, Operating Procedure For The Control And Use Of Vendor Procedure. OP/0/B/6500/53, Operating Procedure For Transfer And Dewatering Of Secondary Resins is used to document the resin transfer and boundary conditions for liner dewatering. This ,

procedure states that physical testing shall be performed if the PCP is not followed. The PCP states that boundary conditions will be established for all process parameters. The process parameters include waste form, settling time, drain (or pump) time and drying time. Waste' form is not specifically addressed i in OP/0/B/6500/53.

Technical Specification 3/4.11.3 states that radioactive waste shall be solidified or dewatered in accordance with the PCP to meet shipping and trancportation requirements during transit, and disposal site requirements when received at the disposal site. This Technical Specification is applicable at all times and requires the following actions:

a. With Solidification or dewatering not meeting the disposal site and shipping and transportation requirements, suspend shipment of the inadequately processed wastes and correct the PCP, the procedures and/or the Solid Radwaste System [EIIS:WB) as necessary to prevent recurrence,

b. With the Solidification or dewatering not performed in accordance with the PCP, test the improperly processed waste to insure that it meets burial ground and shipping requirements and take appropriate '

administrative action to prevent recurrence.

c. The provisions of Technical Specification 3.0.3 are not applicable. i EVENT DESCRIPTION In March 1989, the question of feasibility of loading of bead resin into powdex i

liners, at CNS, was first raised, after the Secondary Chemistry Supervisor noted that the amount of bead resin transferred into a bead resin liner from the CPD Backwash tank was less than the amount transferred from the BB demineralizers to l the CPD Bac;; wash tank. Further investigation by the Chemistry Supervisor found I

that bead resin would tend to settle in the bottom of the horizontal CPD l Backwash tank during sluicing operations. This discovery led the Chemistry l Supervisor.to investigate handling of the possibly mixed media resins in the i bottom of the CPD Backwash tank. The CNSI Site Operator was contacted with the question of the possibility of mixing bead and powdex resin in the same liner. -

l The CNSI Site. Operator contacted a CNSI Operations Supervisor in the Columbia, S.C. headquarters who indicated on March 7, 1989,~that bead and powdex resin-l could be. mixed in powdex liners and dewatered using the powdex dowatering.

l procedure. A follow-up telephone conference with the CNS Radiation Protection (RP) Associate Scientist and the CNSI Barnwell Manager of Regulatory Affairs was O

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s made concerning the proper waste description to be used on the shipping manifest containing the mixed bead and powdex resin. The CNS1 Regulatory Affairs Manager stated that such shipments should be labeled "dowatered filter media" on the

waste descriptions when completing the radioactive shipment manifest. This l

conversation was also documented in a Memorandum To File by the RP Associate Scientist on March 9, 1989. ,

on March 22, 1989, a meeting between Station Chemistry and RP personnel was held

to discuss secondary bead resin handling problems. Topics included mixing bead

! and powdex resins in the same liner, and bead resin sampling problems caused by residual resin in the CPD Backwuh tank. The RP Associate Scientist explained that RP did not have a problem with mixing bead and powdex resin from a sampling standpoint, since the densities and waste streams were virtually the same.

Also, a plan for preventing residual bead resins in the CPD Backwash tank from contaminating clean resin in the CPD Backwash tank was addressed. This meeting was documented in a Memorandum To File by the Chemistry Scientist on April 3, 1989 and copied to Station Chemistry management.- The Corporate Nuclear Chemistry personnel were not involved in this meeting.

l l On April 21, 1989, 33 cubic feet (cf) of bead resin were added to liner serial l number 451804-01. On May 2,.67 cf of powdex resin and 85 cf of bead resin were mixed in the backwash tank and transferred to liner 451804-01 and the liner was subsequently dewatered using the powdex dewatering procedure. On June 7, 18 cf of boad resin were added to the top of liner serial number 448885-28 which had previously been loaded with 88 cf and 79 cf of powdex on October 12,.1988 and February 10, 1989, respectively. Liner serial number 448885-28 was subsequently dewatered per the powdex dewatering procedure.

t l On July 19, 1989, CNSI Barnwell Regulatory Affairs personnel advised the RP Associate Scientist to use the description "dowatered powdex and bead resin" for the mixed media resin liner shipping manifest instead of using "dewatered filter media" as previously stated during the March 7 conversation. On July 26, 1989,

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the two mixed media resin liners were chipped to the Low Level Waste Repository i in Barnwell, S.C.

In December of 1989, McGuire Nuclear Station (MNS) contacted Corporate Nuclear Chemistry and requested permission to dowater bead and powdex resin at MNS. On 1 December 7, 1989, a letter from the DPC Corporate Nuclear Chemistry was sent to CNSI Engineering referring to previous telephone conversations, between Corporate Nuclear Chemistry and CUSI, concerning the possibility of loading powdex and bead resins in the same powdex liner. Thjs letter was initiated after MNS Chemistry had notified Corporate Nuclear Chemistry that they were not able to completely fill bead resing liners due to the amount of water required to sluice. bead resin. Shipments of mixed resin could eliminate this problem and better utilize storage space. The letter stated that DpC was interested in pursuing this for disposal of secondary powdex and bead resin and referred to testing required to determine if mixed loadings are feasible. This letter was

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also copied to the Chemistry Scientist at Catawba Nuclear Station (CNS). Upon receipt of this letter the chemistry Scientist noted that two powdex liners consisting of bead and powdex resin had been previously shipped to the waste 4,

repository at Barnwell, S.C., on July 26, 1989. On December 12, 1989, the L Chemistry Scientirt promptly notified the CNSI Site Operator who was also aware h of the prior shipment, to determine if there was a problem with the 7uly 26, 1989 shipment. The CNSI Site Operator contacted the CNSI Operations Manager who

• stated that it was acceptable to dowater mixtures of bead and powdex resin in powdex liners using the powdex dowatering procedure. The issue of mixed resin liners, however continued to be pursued by the Chemistry Scientist and Corporate Nuclear Chemistry was notified of the problem.

On December 15, 1989, at 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />, Problem Investigation Report (PIR)

, 0-C89-0381 was issued due to a violation of Technical Specification 3/4.11.3.

This was due to two liners of mixed media (powdex and bead resin) being shipped in violation of the PCP. Since the boundary conditions for resin form were not mot, a Technical Specification violation occurred. The conclusion, that l Technical Specification 3/4.11.3 had been violated, was drawn following a telephone conference between Corporate Nuclear Chemistry, Station Chemistry and CNSI Operations and Engineering Departments.

l l Further shipments of mixed secondary resin liners were suspended until testing l of mixed media liners has been performed and the required procedure changes had-

been issued. Resin loading similar to the least conservative liner shipped, on l July 26, has been tested to insure adequate dewatering. The dewatering test

report was issued on February 7,1990. The test report concluded that the mixed resin liners were adequately dewatered and met the Barnwell Site acceptance-criteria. CNSI is issuing a prbcedure to allow dewatering of bead and powdex resin mixtures in powdex resins in powdex liners.

CONCLUSIONS

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Technical Specification 3/4.11.3 was violated due to two liners of bead and powdex resin mixtures being shipped to the Barnwell Low Level Waste Repository, after being dewatered using an inadequate procedure for the type of resin form.

The CNSI procedure used (FO-OP-22, Ecodex-Precoat/Powdex/Solka-Floc /Diatomacious Earth Dewatering Procedure For CNSI 14-215 or Smaller Liners), Enclosure 4.5 of OP/0/B/6500/09, specifies that "this procedure applies only to the dewatering of Ecodex-Precoat/Powdex/Solka-Floc / Diatomaceous Earth or equivalent base forms in CNSI 14-215 or smaller liners with less than 1% oil". The dewatering procedure used was inadequate for the liner loading since it did not include bead resin in the applicability statement. The CNS Chemistry personnel, however, interpreted-the "or equivalent base forms" to include bead resin, since the bead resin and-powdex resin are of the same chemical composition. Also the CNSI Operations and Barnwell Regulatory Affairs Personnel had indicated that bead and powdex resin mixtures could be dowatered in powdex liners using the FO-OP-22 procedure, fu s a .v.s. era,nn .no w,movo

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This incident is assigned a root cause of Management Deficiency, due to inadequate policy or directive, in that the pCP allowed a deviation from the normal practice of handling bead and powdex resin separately to be changed i without the involvement of Corporate Nuclear Chemistry. The involvement of Corporate Nuclaar Chemistry would have provided an additional level of review and would have probably led to consultation with CNSI Engineering. Chemistry is now directed to inform Corporate Nuc1 car Chemistry when any changes to the handling of radioactive waste are anticipated or required.

This incident is assigned a contributing cause of management deficiency, due to poor management interface, in that the CNSI Operations group, Barnwell Site Regulatory Affairs and the CNSI Engineering group had conflicting

- interpretations as to the applicability of Procedure FO-OP-22 to handle mixtures

, of bead and powdex resin. The discussions between station personnel and the CNSI Operaticno and Barnwell Regulatory Aff airs personnel led to the misinterpretation of the procedure applicability.

This Technical Specification violation is also assigned a contributing cause of a possible procedure deficiency, in that the statement "or equivalent base forms" was misinterpreted by the CNSI Operations group, Barnwell Site Regulatory Affairs, and by the CNS Chemistry personnel. Also OP/0/B/6500/53, Enclosure 4.15, Dewatering Record does not specifically list the waste form as a process parameter for which boundary conditions are established. Although the Chemistry Supervisor was aware of the applicability statement in FO-OP-22, listing of the waste form in the boundary conditions may have instigated further review. If the boundary conditions are not met or are in doubt physical testing of the liner can be performed to insure proper dewatering per the PCP. Physical L Testing, per OP/0/B/6500/53, consists of visual inspection and a probe penetrato l test. OP/0/B/6500/09 will be evaluated to determine if clarification of the l applicability statement is warranted. Also, OP/0/B/6500/53 was evaluated to I determine that all process parameters are adequately addressed.

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A review of the Operating Experience Program database for the past 24 months, does not yield any Technical Specification violations due to procedural or management deficiencies. Therefore, this incident is not considered to be a recurring problem or a recurring event.

CORRECTIVE ACTIONS SUBSEQUENT l

1) Shipments of mixed bead and powdex resins were suspended'until test loaded liners were tested ~and any required procedure changes are issued.

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, itxt .a . ,. nc s,. w w nn 3 2) Resin loadings similar to the least conservative liner shipped, on July 27, 1989, were tested to insure adequate dewatering.

/ 3) Chemiatry personnel have been made aware of this incident through significant event notification training.

4) The PCP and/or station procedures concerning radioactive waste shipments was revised to require notification of Nuclear Chemistry when any changes or deviations in the solidification or dewatering of radioactive waste is anticipated or required and may affect the pCP.

b) A clearer term for equivalent base forms in the applicability statement for OP/0/B/6500/09, Enclosure 4.5 (FO-OP-22) was established

, and included in the procedure applicability statement.

6) OP/0/B/6500/53, Operating Procedure For Transfer And Dowatering Cotitaminated Secondary Resins, was evaluated to determine that all process parameters are adequately addressed.

SAFETY EVALUATION The two mixed resin liners (serial. numbers 44885-28 and 451804-01) shipped, on July 26, 1989, have been buried at the Barnwell Low Level Waste Repository.

These liners were dewatered using a procedure that was untested for the mixed resin loading, however, the top of the resin beds were visually inspected and the liners were sounded by the CNSI Site operator prior to shipment. The visual inspection and sounding did not indicate the presence of freestanding liquid in either liner. Subsequent certification testing of a liner loaded with powdex and bead resin using the powdex dewatering procedure, conducted by CNSI, indicates that the mixed resin liners, shipped on July 26, meet the Barnwell Site acceptance criteria for moisture and freestanding liquid. Therefore, the health and safety of the public were unaffected by this incident.

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