ML20132E081

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Insp Repts 50-277/85-31 & 50-278/85-28 on 850729-0801. Violations Noted:Failure to Provide Accurate Radionuclide Activities in Shipping Papers & Excessive Contamination Noted on Exterior of Shipping Package
ML20132E081
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 08/20/1985
From: Bicehouse H, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20132E050 List:
References
50-277-85-31, 50-278-85-28, NUDOCS 8509300379
Download: ML20132E081 (17)


See also: IR 05000277/1985031

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-277/85-31

50-278/85-28

Docket Nos. 50-277

50-278

License Nos. DPR-44 Priority -

Category C

DPR-56

Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, PA 19101

Facility Name: Peach Bottom Atomic Power Station

Inspection-At: Delta, PA

Inspection Conducted: _ July 29 - August 1, 1985

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Inspectors: I

j /k /A (lcw ) .hN k D 6

M J. Ypei se, adiati W SpeQ)alist i

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Approved by: . b bGW Q L O 8.5

W PJ. Pa$ci ak, Chief, BWR Radiological Cate i

Protect %n Section

Inspection Summary: Inspection on July 29 - August 1, 1985 (Combined Report

Nos. 50-277/85-31; 50-278/85-28)-

Areas Inspected: Special, announced inspection of the licensee's transporta-

tion activities (i.e. radioactive materials shipping / receipt and radioactive

waste disposal) including: previously identified items, quality assurance /

quality control, indoctrination and training, procedures, procurement and reuse

of packagings, implementation of the program and incidents. The inspection

involved 33 inspector-hours onsite by a regionally-based inspector.

Results: Three violations were identified, i.e. failure to provide accurate

radionuclide activities in shipping papers (Detail 9.2), certifying transported

materials were accurately described when they were not (Detail 9.2), and

contamination exceeding 220dpm/cm2 on the exterior of a shipping package

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(Detail 9.3).

8509300379 e50925 7

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DETAILS

1.0 Persons Contacted

During the course of this special inspection, the following personnel were

contacted or interviewed:

1.1 Licensee Personnel

D. Ahmuty, Administrative Assistant-Training

T. Donnell, Quality Control Supervisor

  • A. Hilsmeir, Senior Health Physicist
  • W. Knapp, Director, Corporate Radiation Protection Section

G. McCarty, Support Health Physicist

J. McElwain, Quality Control Engineer

  • R. Moore, Lead Auditor, Quality Assurance

C. Nelson, Applied Health Physicist

P. Pauly, Radwaste Supervisor

  • D. Smith, Superintendent-Operator

R. Smith, Physicist

D. Wheeler, Test Engineer, Reactor Engineer

J. Wilson, Quality Assurance Supervisor .

Other licensee personnel were also contacted or interviewed during

this inspection.

1.2 NRC Personnel

T. Johnson, Senior Resident Inspector

  • J. Williams, Resident Inspector
  • Attended the exit interview on August 1, 1985.

2.0 Purpose

The purpose of this special safety inspection was to review the licensee's

transportation activities in the areas of radioactive materials receipt

and shipping and radioactive waste (radwaste) disposal with respect to the

following elements:

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Previously Identified Items

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Quality Assurance / Quality Control

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Indoctrination and Training

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Procedures

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Procurement and Reuse of Packagings

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Implementation

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Incidents

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3.0 Previously Identified Items

3.1 (Closed) Inspection Followup Item (50-277/84-09-05) Determine if

audits are adequate. Audit Report No. AP84-67HPL, Radwaste/ Material

Handling and Shipping", (October 16, 1984 - December 10,1984),was

reviewed relative to criteria to 10 CFR 50, Appendix B applicable to

shipping. Audit Report No. AP84-67HPC addressed each criterion of 10

CFR 50, Appendix B and was comprehensive in terms of the licensee's

site shipping activities. The audit was conducted by a trained

quality assurance auditor. This item is closed. See related

information in Section 4.1 of this report.

3.2 (Closed) Violation (50-277/84-42-02) Failure to provide QC Program in

accordance with 10 CFR 20.311(d)(3). Actions described in the

licensee's letter (dated February 28,1985), were reviewed. The

licensee completed actions as described in the response letter. This

item is closed. -

. 3.3 (Closed) Inspection Followup Item (50-277/84-42-03) Licensee's

actions regarding NRC Information Notice No. 84-72 for solified

contamination resin shipment. The licensee developed Special

Procedure 769, " Final Verification of Opening And Venting of CNS

6-80-2 Cask", (June 24, 1985), and Special Procedure 775, " Gas

Sampling of Cask Using Marinelli Beaker", (January 23,1985),in

response to this item. The procedures adequately addressed gas

generation concerns. This item is closed.

4.0 Quality Assurance (QA)/ Quality Control (QC)

A QA program is required for transport packages in accordance with the

provisions of 10 CFR 71, Subpart H. A Commission approved QA program

which satisfies the applicable criteria of Appendix B of 10 CFR 50 and

which is established, maintained and executed with regard to transport

packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.

.The licensee elected to apply their currently established 10 CFR 50,

Appendix B, QA program to the packaging and transportation of radioactive

material.

In addition to the general QC provisions required by 10 CFR 50, Appendix

B, specific QC requirements to assure compliance with 10 CFR 61.55 and

61.56 are required by 10 CFR 20.311.

The packaging and transportation QA/QC activities implemented by the

licensee's site QA and QC organizations was reviewed.

4.1 Audits / Appraisals

The licensee's program for audits of radwaste/ material shipment

activities (including radwaste preparation and classification) was

i reviewed against requirements, commitments and guidance provided in:

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10 CFR 50, Appendix B, Criterion XVII, " Audits";

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Technical Specification 6.5, " Review And Audit";

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Peach Bottom Atomic Power Station, Units 2 and 3 Quality

Assurance Plan; and

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NRC-IE Information Notice 84-50, " Clarification of Scope of

Quality Assurance Programs for Transport Packages Pursuant to 10

CFR SC, Appendix B."

.The licensee's performance in this area was determined by interviews

of site QA personnel, examination of Quality Assurance Division Pro-

cedures for scheduling, performing, reporting and closing audits and

review of Audit Reports Nos. AP 84-67HPC and AP 83-04HPC.

The inspector noted that:

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corrective action measures initiated as a result of audit find-

ings are reviewed for implementation on followup audits;

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adequate QA procedures and checklists were used in auditing

shipping activities; and

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a review of the QA program was conducted in 1984 to ensure that

the licensee had adequate procedures to implement the QA plan

for transport packages.

Within the scope of this review, no violations were identified. The

licensee has implemented an audit program for shipping activities

addressing applicable criteria in 10 CFR 50, Appendix B.

4.2 Surveillance / Inspection Activities

The licensee's program for surveillance and inspection activities was

reviewed against criteria provided in 10 CFR 50, Appendix B,

Criterion X, " Inspections" and commitments in the licensee's approved

QA plan. The licensee's performance relative to these standards was

determined by interviews of site QC personnel, review of procedures

and other documents and observation of QC inspection activities

during Shipment No. 173-85.

Tne site QC organization provides surveillance and inspections cover-

ing radwaste/ material shipment activities (including radwaste pre-

paration). Detailed Monitoring Checklists have been developed for

-surveillance activities. Mandatory inspection hold points in plant

operating procedures related to shipping require witnessing or

inspection by QC personnel prior to continuation of the procedures.

Within the scope of this review, no violations were noted. The

licensee has implemented a generally effective surveillance and

inspection program.

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4.3 Radwaste Generator QC Program '

Under 10 CFR 20.311(d)(3), each licensee is required to conduct a

quality control program to assure compliance with 10 CFR 61.55 and

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61.56 requirements for waste classification and waste characteris-  !

tics. The licensee's performance in this area was determined by:

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review of procedures for preparation of radwaste shipments; j

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examination of records relating to shipments of dewatered

resins, control rod blades and dry active waste;

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review of actions taken regarding findings in Combined Inspec-

tion Reports Nos. 50-277/84-09; 50-278/84-09 and 50-277/84-42

50-278/84-34; and  !

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discussions with cognizant health physics and operations l

personnel.

Within the scope of this review, no violations were noted.

5.0 Indoctrination and Training

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The general indoctrination and specific training of personnel assigned to

radioactive materials shipping activities were reviewed relative to

criteria provided in 10 CFR 50, Appendix B, Criterion II, " Quality

Assurance Program", and commitments in the licensee's response to NRC-IE

-Bulletin No. 79-19, " Packaging of Low-level Radioactive Wastes for Trans-

port and Burial". Selected training records for operations, health

physics, quality control and maintenance personnel were reviewed and

representatives from each group were interviewed regarding training for

use of the FSV-1 cask in irradiated control rod shipments and dewatered

resins in HN-100 series casks.

Within the scope of this review, no violations or deviations were noted.

6.0 Procedures

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The licensee's procedures for selected shipping and receiving activities

were reviewed relative to criteria provided in 10 CFR 20.205, 10 CFR 71

and Technical Specification 6.8, " Procedures", Procedures in the HP0/C0-71

series, HP0/C0-17 series and selected fuel handling procedures were 1

reviewed to determine if instructions concerning acceptance criteria and '

regulatory limits were provided for-

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receipt of shipments containing radioactive materials, i.e. previous- 1

-ly used casks supplied by contracted vendors;

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selection of packaging for licensee-initiated shipments;

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preparations for shipments;  !

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maintenance of packaging;

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marking and labeling shipments and placarding vehicles;

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monitoring shipments for radiation and contamination; and

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providing shipments of radwaste meeting disposal site acceptance

criteria.

In addition, the licensee's procedures for preparation, classification,

packaging and shipping radwaste were reviewed against criteria contained

in:

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10 CFR 20.311, " Transfer for Disposal and Manifests"; and

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NRC-NMSS Low-level Waste Licensing Branch, " Final Waste Classifica-

tion and Waste Form Technical Position Papers", (May 1983).

6.1 Health Physics / Chemistry Operating (HP0/CO) Procedures

The licensee's procedures for receipt of radioactive materials,

(HP0/C0-16), shipment of radioactive materials, (HP0/CO-17 series),

handling high integrity containers, (HP0/C0-70), and selected casks

shipments, (HP0/CO-71 series) were reviewed and discussed with health

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physics personnel. Special emphasis was placed on the review of QC1

hold and inspection points.

Within the scope of this review, the following items were noted:

HP0/CO-17C, " Compliance with 10 CFR Part 61", Revision 0 (March 19,

1984) contained several errors in technical content:

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Section B, (Page 2), referred to Appendix D, however, the

correct reference was Appendix C of the procedure;

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Section D, (Page 4), indicated that a description of the Atomic

Industrial Forum's method of waste classification was provided

in Appendix C, but it was not;

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Section F.1.d (Page 6) omitted the words, " explosive reaction",

while discussing requ,irements in 10 CFR 61.56(a)(4);

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Appendix A, Table 1 " Classification of Wastes" did not list

Nb-94 and had incorrect units for transuranic materials with

half lives greater than 5 years (i.e. Pu-241 and Cm-242) listing

those materials in curies per cubic meter instead of nanocuries

per gram; and

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Appendix A, Table 2 listed incorrect Class B limits for Sr-90,

incorrect Class C limits for Sr-90 and an incorrect limit for

unacceptable levels of Sr-90.

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In addition, HP0/CO-17C failed to discuss 10 CFR 61.55(a)(5) concern-

l ing classification by long and short-lived radionuclides and the " sum

of the fractions" rules in 10 CFR 61.55(a)(7).

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These errors in technical content in HP0/C0-17C were discussed with

the licensee and will be reviewed in a subsequent inspection,

50-277/85-31-01; 50-278/85-28-01.

6.2 Fuel Handling (FH) Procedures

The following fuel handling procedures related to the preparation,

packaging and shipping of irradiated control rod blades were

reviewed:

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FH-48A, " Control Rod Corner Shearing Procedure", Revision 2,

(May 15, 1985); .

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FH-48B, " Control Rod Burial Liner Loading Procedure", Revision

3, (June 13, 1985);

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FH-48C, " Handling of the FSV-1 Casks", Revision 13, (July 24,

'1985); and

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FH-480, " Radiation Survey of Spent Control Blades", Revision 0,

(March 7, 1984).

Previous revision (to Revision 0) of FH-48A, FH-48B and FH-48C were

also reviewed to note developments technical changes in the

licensee's handling and shipping of irradiated control rod blades

since 1983.

Within the scope of this review, the following items were noted:

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FH-48C failed to provide acceptance criteria for radiation dose

rates associated with collected drainage water from the loaded

FSV-1 cask at Step H-4. Although health physics technicians

were required to record measured dose rates on small quantities

of collected drainage water, acceptable dose ' rates for collected

water were not provided. Acceptance criteria were necessary

since the dose rates could be high if radioactive chips

associated with the shearing of the satellite rollers were

contained in the drainage. In addition, the collected drainage

water discharged to a floor drain and the water's acceptability

to the liquid radwaste shipment must be determined prior to

discharge.

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FH-48C failed to instruct crafts and quality control personnel

to ensure that the entire sealing surface was " soap" tested at

Step H-21. This " soap" test provides a test for cask leakage

following pressurization in earlier steps. If the entire

, sealing surface being tested is not covered with soap solution,

i an uneven pressure differential is created between the

pressurized cask and the surrounding atmosphere. Leakage gas

would need to overcome the soap solution surface tension plus

atmospheric pressure in one area and only atmospheric pressure

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in unsoaped areas. The sensitivity of the leak test method

could thus be compromised.

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Final cask draining to remove water trapped in the two inverted

control rods' velocity limiters at Step H-2 and succeeding steps I

could lead to radioactive contamination of the trunion area. See

related item in Section 9.3 of this report.

These items were discussed with the licensee and will be reviewed in

a subsequent inspection. 50-277/85-31/02; 50-278/85-28-02.

6.3 QC Procedures

The following Detailed Monitoring Checklist (DMC) used by QC inspec-

tors reviewing radwaste preparation and shipping operations were

reviewed:

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DMC 4.1, "Radwaste Shipping", (August 27,1984);  ;

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DMC 4.2, "Radwaste Packaging and Storage", (March 1984); and

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DMC 4.3, "Radwaste Solidification", (April 3, 1984).

Within the scope of this review,' no items of noncompliance were

noted.

7.0 Procurement and Reuse of Packagings ,

The licensee's' program for selection of packages was reviewed against

requirements of 10 CFR 71.12. " General License: NRC Approved Package", and

the DOT requirements of 49 CFR 173, " Shippers - General Requirements for

Shipments and Packagings". Records for 21 shipments were reviewed and

discussed with the licensee to determine that: ,

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for shipment in packages which the licensee had registered to use,

the licensee possessed copies of the specific NRC or Agreement State .

Certificate of Compliance, drawings, procedures and referenced *

documents;

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the licensee's practices regarding use and maintenance were in

accordance with the applicable certificates and other documents

referenced in the certificate; and

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for NRC-certified pa'ckages, the licensee had registered with NRC-NMSS

prior to the first use of the package.

Within the scope of this review, no violations were identified. --

8.0 Implementation

The implementation of the licensee's program for transportation of

radioactive material was reviewed against criteria contained in 10 CFR 71, -

49 CFR 172-173 and the licensee's procedures. For radwaste shipments,

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criteria in 10 CFR 20.311 and 10 CFR 61.55 and 61.56 were also used in the

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review. Each shipment examined was reviewed to determined the adequacy

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radiation and contamination measurements;

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shipping paper documentation;

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package marking and labeling;

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loading and storage of packages;

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vehicle placarding; and

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notification to state agencies for shipments of radwaste (as

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applicable under 10 CFR 71.97).

The licensee's performance relative to these requirements was determined

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observation of shipment No. 173-85 (dewatered resin shipment);

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review of shipping records and other documents related to 8 Low

[ Specific Activity (LSA) solidified drum and dry active waste box

l shipments, 8 irradiated control rod blade shipments in 1984 and 1985

! and 5 Certificate of Compliance cask shipments of dewatered resins;

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discussion with licensee personnel.

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9.0 Incidents

l Three problems associated with radwaste shipments reported by the licensee

were reviewed to determine that:

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the event was reported in a timely manner;

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the report made by the licensee was adequate;

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the licensee took prompt corrective actions; and

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those corrective actions were adequate to prevent recurrence.

9.1 Shipment No. 103-85 (Solidified Waste Drum)

On May 30, 1985, a representative of the State of Washington,

Department of Social and Health Services identified a " puncture hole"

j in Drum No. S-146-85 (one of a number of low specific activity (LSA)

drums in Shipment No. 103-85). This problem was the subject of

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enforcement action by the State of Washington and a Notice of

Violation from the NRC (see Combined Inspection Report Nos.

50-277/85-27; 50-278/85-25).

l Actions taken by the licensee to identify the cause(s) of this

l problem and to take corrective action were reviewed. The licensee

! verified that a " puncture hole" in Drum No. S-146-85 was present and

postulated that it was caused by fork lift handling devices used by

the licensee. Corrective actions included:

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revision of HP0/CO-71G, " Loading of a Radioactive Waste Shipping

Van", and HP0/C0-71I, " Solidification, Packaging and Inspection

of Liquid and Materials in Preparation for Shipment", to reduce

the likelihood of damage during handling preparatory to

shipment;

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examination of fork lift handling devices for possible causes;

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precautionary instructions to fork lift operators; and

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increased attention by QC personrel.

Although the licensee's actions appeared to be adequate, it was

unclear that handling preparatory to shipment had punctured the drum.

- 9.2 Shipment No.145-85 (FSV-1 Cask)

On July 7,1985, an FSV-1 cask containing 4 irradiated control rod

blades was sent for disposal at the low-level waste burial site in

South Carolina. Shipping papers sent with shipment indicated that

the cask contained 4 f rradiated control rod blades in cask liner No.

10. In reality, cask liner No. 98 had been loaded and shipped in the

FSV-1 cask. The differences between the original shipping papers

description and the actual description of the shipment are shown

below:

Original Shipping Actual Shipment

Papers

Liner No. 10 98

  • Total Activity 4,984.6 curies 7,643.5 curies

224.6 "

Technetium-99 0.0047 " 0.0065 "

  • Iodine-129 4.8E-8 " 4.8E-8 "

Waste class C C

  • Dose Rate (liner 12,300. 19,600.

contact R/hr) *

Advance notification to the states (under 10 CFR 71.97) sent by the

licensee's Reactor Engineering group on June 28, 1985 correctly

indicated a total activity of 7,645 curies and reflected the radio-

nuclidic activities in liner No. 98. The original shipping papers

contained a certification that the transport materials were properly

described in the shipping manifest (shipping papers). The following

violations associated with Shipment No. 145-85 were identified:

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10 CFR 71.5(a) requires each licensee who delivers licensed

material to a carrier for transport to comply with the require-

ments of the regulations appropriate to the mode of transport of

the Department of Transportation (00T) in 49 CFR Parts 170

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through 189. 49 CFR 176.203(d)(iii) requires that the activity

contained in each shipment be included in the shipping papers.

Contrary to these requirements, shipping papers accompanying

Shipment No.145-85 on July 7-9, 1985, incorrectly listed the

individual radionuclide activities and the total activity.

Failure to include accurate activities in Shipment No. 145-85

shipping papers constitutes a violation of 10 CFR 71.5(a)

50-277/85-31-03; 50-278/85-28-03.

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10 CFR 20.311(c) requires, in part, that each shipping manifest

include a certification by the waste generator that the trans-

ported materials are properly described.

Contrary to this requirement, the shipping manifest accompanying

shipment No. 145-85 on July 7-9, 1985, certified that the transported

materials were properly described when the individual and total

activities of the radionuclides listed on the shipping, manifest were

incorrect. Certification that the transported materials were

properly described when the individual activities and total activity

in shipment were incorrectly listed constitutes a violation of 10 CFR

20.311(c). 50-277/85-31-04; 50-278/85-28-04.

On July 9, 1985, during discussions between Reactor Engineering and

Health Physics personnel, the licensee recognized that shipping

papers and manifests accompanying shipment No. 145-85 were incorrect.

The following corrective actions were taken:

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Shipping papers and manifests reflecting the correct activities

were prepared;

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The low-level waste burial site was telephoned and requested to

hold Shipment No. 145-85 to prevent removal and burial of the

liner;

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A physicist was sent to South Carolina on July 9, 1985 with the

corrected shipping papers and waste manifest;

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The licensee informed the Senior Resident Inspector of the

problem on July 9, 1985;

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Procedure HP0/C0-71Y, " Shipment of the FSV-1", Revision 0, (July

24,1985) was prepared which provided a verification by Health

Physics and QC personnel that the liner serial number in the

FSV-1 cask was consistent with the serial number on the shipping

papers and waste. manifest;

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Procedure FH-48C, " Handling of the FSV-1 Cask", was revised to

j include a QC verification of liner serial number (Step F-2 of

, the procedure); and

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The licensee suspended control red blade shipments voluntarily

until-the corrective measures were ,in place.

The inspector noted that.the safety significance of this incident was

lessened by.the following considerations:

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actions to be taken in the eventi of a mishap in transport would

not have been significantly affected by the errors in total

activity and liner contact radiation levels; and

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actions to prevent exposure at the low-level waste burial site

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for these shipments _are based on contact liner dose rates up to

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30,000 R/hr.

9.3 Shipment No.169-85 (FSV-1 Cask)

On July- 26,1985, 'the licensee shipped a FSV-1 cask containing 4

irradiated control rod blades to the low-level waste disposal site in

South Carolina. On July 30, 1985, the licensee reported that

representatives of the low-level burial site had discovered removable

radioactive contaminatio1 on the trunion cup area of the FSV-1

cask / trailer interface. This area is accessible for contamination

measurements only when the cask is separated from the trailer. The-

contamination levels reported by the low-level waste burial site

operator were'18,000 disintegrations per minute per 100 centimaters

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squared (dpm/1002), 32,000 dpm/100cm2 ,-and 48,000 dpm/100cm' Jn

' July 30, 1985, a physicist and a test engineer were sent to ' 'e

low-level = waste burial site by the licensee to investigate 'ae

contamination.

On July 31, 1985, the physicist reported that measurements made by

the licensee confirmed the presence of removable contamination on the

trunion cup area of the _FSV-1 cask / trailer interface. Other areas of

the FSV-1 cask and trailer were uniformly measured to be less than

u 1,000 dpm/100cm2 removable contamination. Recorded removable con-

<- tamination measurements made by the licensee on July-26, 1985, also

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.showed less than 1,000 dpm/100 cm2 on the accessible areas of the

FSV-1 cask and trailer immediately prior to shipment. However, the

trunion cup had not been measured for removable contamination since

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the loaded cask had been joined to the trailer.

During the licensee's review of the events surrounding the removable

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contamination,_a contractor health physics technician reported that

he had observed residual water in the vent / drain operation as the

venting apparatus was_being removed. The vent / drain operation

removes residual fuel pool water retained by the two inverted control

.-'O rods' velocity limiters. During this operation, the cask and trunion

cup are mated and the cask is lowered from a vertical orientation to

one approximately 30 degrees from the horizontal. Nitrogen gas

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pressure is applied to expel the final residual fuel pool water in

the velocity limiters which has been mobilized by placing the cask at

the 30 degree angle to the horizontal. Removal of the vent tube

causes the escape of small amounts of retained fuel pool water. The

vent tube apparatus is positioned in an area that would allow

drainage between the cask and the trunion cup area.

On August 6,1985, the NRC Region II State Agreement Officer con-

tacted the South Carolina Department of Health and Environmental

Control. The State of South Carolina's radiological controls

personnel have evaluated the removable radioactive contamination

associated with Shipment No. 169-85. No action was taken by the

state because the surface contamination was not accessible because

(1) it was located inside the trunion cup and (2) the area was

wrapped.

The following violation associated with Shipment No. 169-85 was

noted:

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10 CFR 71.87(1)(2) requires, in part, that levels of non-fixed

(removable) radioactive contamination on the external surfaces

of each package offered for shipment as exclusive use shipments

not exceed 220 dpm/cm2 at any time during transport.

Contrary to this requirement, non-fixed radioactive contamina-

tion in the trunion cup area of the FSV-1 cask / trailer used in

Shipment No. 169-85 to the low-level waste burial site in South

Carolina exceeded 220 dpm/cm2 on July 30, 1985, upon arrival.

Non-fixed radioactive contamination was measured to be 320 and

480 dpm/cm 2 . The presence of non-fixed radioactive contamina-

tion on Shipment No. 169-85 exceeding 220 dpm/cm2 upon arrival

at the low-level waste burial site constitutes a violation of 10

CFR 71.87(1)(2). 50-277/85-31-05; 50-278/85-28-05. The inspec-

tor noted that the presence of the removable radioactive con-

tamination in the trunion cup area presented little risks to the

public since the area is inaccessible during transport. How-

ever, the removable contamination was accessible during cask

unloading and presented a radioactive contamination problem to

the low-level waste burial site operators.

10.0 Exit Interview

The inspector met with the licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection. The inspector summarized the

scope of the inspection and the findings. The inspector expressed his

concern over the problems noted in the control rod blade shipments. The

licensee's representative indicated that licensee management shared that

concern and intended to take additional action to identify and correct the

causes for the problem.

,

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14

At no time during this inspection was written material provided to the

licensee by the inspector. No information except from disclosure under 10

CFR 2.790 is discussed in this report.

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