ML20135E578
| ML20135E578 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/20/1985 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20135E560 | List: |
| References | |
| 50-348-85-34, 50-364-85-34, NUDOCS 8509160451 | |
| Download: ML20135E578 (8) | |
See also: IR 05000348/1985034
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET.N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.- 50-348/85-34 and 50-364/85-34
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Licensee: Alabama Power Company
600 North 18th Street
Birmingham, AL 35291
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Docket Nos.: .50-348 and 50-364
Facility Name:
Farley 1 and 2
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Inspection Conducted: August 5-9, 1985
Inspector:
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R. E. W(ddington d
Date Signed
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Accompanying Personnel:
M. Poston-Brown
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Approved by: w
~. M. Hosey, Section Chief
D6te S'igned
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Division of Radiation Safety and Safeguards
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SUMMARY
Scope: This routine, unannounced inspection entailed 40 inspector-hours onsite
in the areas of follow-up on a transportation event, 10 CFR Part 61,
transportation of radioactive material, control of radioactive material, external
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exposure control, internal exposure control, ALARA and IE Information Notices.
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Results: Three violations were identified: (1) failure to adhere to the license
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conditions of a low level radioactive waste disposal site, (2) failure to
adequately prepare a procedure for dewatering radioactive sludge lancing filters
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and (3) failure to adequately review a waste handling procedure.
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8509160451 850828
ADOCK 03000340
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
J. D. Woodard, Plant Manager
D. N. Morey, Assistant Plant Manager - Operations
C. D. Nesbitt, Technical Superintendent
W. B. Shipman, Assistant Plant Manager - Support
R. D. Hill, Operations Superintendent
W. G. Ware, SAER Supervisor
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P. E. Farnsworth, Health Physics Sector Supervisor
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J . M. Walden, Radwaste Supervisor
J. A. Morrow, Radwaste Technician
D. E. Grissette, Environmental and Emergency Preparedness Supervisor
Other licensee employees contacted included two foreman, four technicians,
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and two office personnel.
NRC Resident Inspectors
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W. H. Bradford, Senior Resident Inspector
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2.
Exit Interview
The inspection scope and findings were summarized on August 9,1985, with
those persons indicated in paragraph I above.
The following issues were
discussed in detail: (1) an apparent violation for failure to adhere to the
license conditions of a low level radioactive waste disposal site
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(paragraph 4.a), (2) an apparent violation for failure to adequately prepare
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and review a procedure for dewatering radioactive sludge lancing filters
(paragraph 4.b) and (3) 10 CFR Part 61 scaling factors (paragraph 5). The
licensee acknrwiedged the inspection findings ar.d stated that they did not
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consider the apparent violation for failure to comply with disposal site
requirements to be appropriate since they had already been cited for the
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violations by the State of South Carolina.
3.
Licensee Action on Previous Enforcement Matters
(Closed) Unresolved * (50-348/85-20-05) - Failure to post a contaminated
area.
This item concerned an entry by the resident inspector into an
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unposted contaminated area in the hallway adjacent to the boric acid
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"An Unresolved Item is a matter about which more information is required to
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determine whether they are acceptable or may involve violations or deviations.
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A
batching area on the 100' elevation of Unit 1 on May 2, 1985, which resulted
in his shoes becoming contaminated.
The item was left unresolved pending
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review of the licensee's posting practices by a regional health physics
inspector.
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By examination of selected records and interviews with licensee health
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physics personnel, the inspector deternur,ed that a portion of the area in
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question had been surveyed for release after decontamination the previous
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shift and health physics personnel were in the process of moving the
contamination control barriers. Due to a shift change delay, one access to
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the area was not posted as a contaminated area at the time the resident
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inspector entered the area.
Health physics personnel were at the other
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access to the area and promptly took.necessary action to warn the resident
inspector and provide assistance. Through review of selected licensee event
reports and observations of licensee postings during facility tours, the
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inspector determined that there had been no other problems of this nature.
Due to the isolated nature of this event, the short period of the time the
one access was not posted and the fact that health physics personnel had
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returned to the area and would have likely effected the necessary controls
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shortly thereafter, it was determined that no violation of regulatory
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requirements had occurred and the item was closed.
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4.
Transporation Event (93702)
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a.
During the first quarter of 1985, the licensee had a contractor onsite
performing sludge lancing of the. secondary side of the steam generators
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of both units.
A byproduct of this work were bag-type filters
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containing the residue of the sludge lancing.
The sludge lancing
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contractor had dewatered each bag filter using a vacuum drying
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technique and then placed them in poly bags inside of 55 gallon drums.
Each poly bag contained approximately 20 filters and. each - drum
contained approximately six poly bags. A total-of 84 drums of these
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dewatered filters were generated by the contractor.
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In May 1985, the licensee began preparations for shipping this waste to
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a disposal site. A licensee representative stated that prior to the
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shipment he'had opened seven drums of waste (one from each _ of the six
steam generators and one random drum) to perform a visual inspection
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for free standing water in selected bags and to obtain samples for
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10 CFR Part 61 compliance determinations. The licensee representative
stated that'he had observed no free standing water in the bags he had -
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examined. The~ drums were shipped from the licensee's site on May 30,
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1985, under control number RWS 85-14.
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On June 4, 1985, the licensee was informed by the Barnwell, South
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Carolina disposal site operator that one of the waste drums had been
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found to contain free standing water in excess of the 0.5% of waste
volume
limit permitted by the
facilities'
license.
Licensee
representatives traveled to the disposal site on June 6,
1985, to
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inspect the shipment. The disposal site operator agreed to inspect the
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entire shipment and determined that 33 of the 84 drums contained free
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standing water, seven of which exceeded the disposal site criteria of
0.5% of the waste volume.
A total of 7.3 gallons of liquid was
collected, with the largest quantity of liquid in any one drum being
1.5 gallons (2.7% of the waste container volume).
The liquid was
solidified at the disposal site and the shipment was then accepted for
burial.
By letter dated June 12, 1985, the Department of Health and Environ-
mental Control, State of South Carolina, informed the licensee that
they had determined that the problems encountered with the dewatered
sludge
lancing
filters constituted two violations of License
Number 097, Amendment Number 41, issued to Chem-Nuclear Systems, Inc.,
the disposal site operator. The first violation issued by the State of
Carolina, was against License Condition 35, which required that sludges
be solidified.
The sludge in the bag filters had been dewatered by
vacuum drying. A licensee representative stated that a representative
of the disposal site operator had egreed prior to the shipment that the
dewatering technique would be acceptable.
However, there was no
documentation of this agreement with the site operator and no
coordination had been made with the State.
The second violation was against License Condition 32, which required
that the waste have no detectable free standing liquids in excess of
one-half percent by waste volume of non-corrosive liquids per
container. Seven drums were found to contain free standing liquid in
excess of the license limit.
The State of South Carolina did not
impose a civil penalty on the licensee or suspend their shipping
priviledges for these violations.
10 CFR 30.41(c) required that before transferring byproduct material to
a specific licensee of an Agreement State, the licensee transferring
the material shall verify that the transferee's license authorizes the
receipt of the type, form, and quantity of byproduct material to be
transferred.
Failure of the licensee to verify their waste shipment
met the disposal site requirements to solidify the sludge waste as
required by License Condition 35 and to meet the free standing water
limit of License Condition 32 was identified as an apparent violation
of 10 CFR 30.41(c) (50-348, 364/85-34-01).
b.
Technical Specification 6.8.1 required that written procedures be
established covering
the applicable procedures recommended in
Appendix A of Regulatory Guide 1.33, Revision 2,
1978.
Regulatory
Guide 1.33, Revision 2,1978, Appendix A, paragraph 7.b.(1) recommends
procedures for filter sludge handling.
Technical Specification 6.5.3.1 required that procedures required by
Technical Specification 6.8 shall be reviewed by an individual / group
other than the individual / group which prepared the procedure.
The inspector reviewed licensee engineering technical procedure,
FNP-1-ETP-4114, Steam Generator Sludge Lancing and Water Balance,
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Revision 1, February 22, 1985, which was the procedure used to control
the contractor's sludge lancing operation.
The licensee procedure
implemented a contractor procedure for the sludge lancing. A licensee
representative stated that packaging of the waste sludge filters for
disposal was within the scope of the procedure. The inspector observed
that vacuum drying of the sludge filters and packaging of the filters
in poly bags and drums was not addressed in the procedure.
The
procedure had been approved by the licensee's Systems Performance
Supervisor and had not been reviewed by the Health Physics staff.
Failure to adequately establish a procedure for handling the waste
sludge filters was identified as an apparent violation of Technical Specification 6.8.1 (50-348, 364/85-34-02).
Failure to adequately
review the procedure for sludge lancing was identified as an apparent
violation of Technical Specification 6.5.3.1 (50-348, 364/85-34-03).
5.
10 CFR Part 61 Scaling Factors (84722)
10 CFR 20.311(d)(1) required that licensees who transfer radioactive waste
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to a land disposal facility prepare all wastes so that the waste is
classified according to 10 CFR 61.55 and meets the waste characteristic
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requirements of 10 CFR 61.56.
10 CFR 61.56 specified the waste
characteristic and stability requirements for low level radioactive waste.
Through discussions with licensee representatives and review of selected
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records, the inspector determined that waste stability, when required, was
achieved by use of approved containers or by solidification in accordance
with the licensee's Process Control Program.
10 CFR 61.55(a)(8) requires
that the concentration of a radionuclide may be determined by indirect
methods such as use of scaling factors which relate the inferred
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concentration of one radionuclide to another that is measured if there is
reasonable assurance that the indirect methods can be correlated with actual
measurements.
The licensee had identified approximately twenty-four waste streams at their
facility and had developed unique scaling factors for each. Through review
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of selected records, the inspector determined that scaling factors were
being appropriately used to classify low level radioactive waste shipments.
A licensee representative stated that they were considering implementing a
contractor prepared Part 61 compliance program. The inspector reviewed a
comparison study the licensee had performed of radionuclide concentration
calculations using the proposed contractor scaling factors. The majority of
the calculated radionuclide concentrations were less than the actual
measured concentration, with several being nonconservative by as much as a
factor of a thousand.
The proposed scaling factors therefore were not
consistent with the requirements of 10 CFR 61.55(a)(8) since the comparison
study showed that there was not reasonable assurance that the indirect
method correlated with actual measurements. This same discrepancy was noted
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in February 1984, (Inspection Report Nos. 50-348,364/84-06), at which time
the licensee committed to resolve the discrepancies prior to implementing
their contractor's program.
The licensee acknowledged the fact that
discrepancies did exist and stated that they were pursuing means of
implementing
their contractors
program consistent with
regulatory
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requirements.
A licensee representative stated that their contractor's
program appeared to be consistent with NUREG/CR-4101, Assay of Long-Lived
Radionuclides in Low-Level Wastes From Power Reactors, April 1985.
The
inspector stated that the NRC Low-Level Waste Licensing Branch Technical
P_ osition Paper, May 11, 1983, would continue to be used by the NRC to
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determine compliance with 10 CFR Part 61 until rescinded or modified.
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No violations or deviations were identified.
6.
Transportation (86721)
10 CFR 71.5 required that-licensees who transport licensed material outside
the confines of its plant of other place of use, or who delivers licensed
material to a carrier for transport, shall comply with the applicable
requirements of the regulations appropriate to the mode of transport of the
Department.of Transportation in 49 CFR Parts 170 through 189.
The inspector reviewed selected records of radioactive waste and radioactive
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material shipments performed during 1985 and verified that the requirements
of 49 CFR Parts 170 through 189 had been met for those shipments.
No violations or deviations were identified.
7.
Control of Radioactive Material (83726)
10 CFR 20.201(b) required each licensee to make or cause to be made such
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surveys as (1) may be necessary for the licensee to comply . with the
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regulations and (2) are reasonable under the circumstances to evaluate the
extent of radiation hazards that'may be present.
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During tours of the facility,- the inspector observed health physics
technicians performing radiation and contamination surveys.
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The inspector performed independent radiation surveys in the auxiliary
building, in the low-level radioactive waste storage building and around
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outside areas of .the plant site and verified that the areas were properly
controlled.
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The inspector discussed a recent event at another Region II facility where
several skin of the whole body exposures resulted from high activity
cobalt-60 (Co-60) particles remaining in laundered protective clothing. The
licensee has had a similar problem in that their laundered protective
clothing had been found in the past to contain residual metal filings. The
activity of the particles discovered normally ranged from 3,000 to 30,000
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disintegrations per minute (dpm), with the highest activity being
approximately 100,000 dpm. These activities were much smaller than those
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encountered by the licensee that had the Co-60 particle problem.
These
filings also contained Co-58, Mn-54, Zr-95 and other radionuclides in
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addition
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Through review of selected records of skin
contaminations, individual exposure records and discussions with . Itcensee
representatives, it was . determined that none of the skin contamination
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events had caused any individual to receive a significant skin exposure.
Through observations and discussions the inspector determined that the
licensee had taken appropriate action to correct the problem with residual
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contamination in laundered protective clothing.
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No violations or deviations were identified.
8.
External Exposure Control and Dosimetry (83724)
10 CFR 20.101 specified the applicable radiation dose standards.
The
inspector reviewed the computer printout dose summary (Form NRC-5
equivalent) for the inspection period and verified that the radiation doses
recorded for plant personnel were well within the quarterly limits of
10 CFR 20.202 required each licensee to supply appropriate personnel
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monitoring equipment to specific individuals and require the use of such
equipment.
By review of selected records and discussions with licensee
representatives, the inspector determined that appropriate personnel
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monitoring equipment was being supplied. During tours of the facility, the
inspector observed that personnel monitoring equipment was being properly
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worn.
No violations or deviations were identified.
9.
Internal Exposure Control (83725)
10 CFR 20.103(a) established the limits for exposure of individuals to
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concentrations of radioactive materials in air in restricted areas. This
section also required that appropriate bioassays be performed to detect and
assess individual intakes of radioactivity.
The inspector reviewed selected results of bioassays (whole body counts) and
the licensee's assessment of individual intakes of radioactive material
performed during the period January - June 1985.
During discussions with
licensee representatives the inspector determined there was a general lack
of familiarity on the part of the dosimetry staff on various technical
aspects of internal dosimetry. The dosimetry function does not have direct
oversight by a health physics professional since the licensee has elected to
place the dosimetry staff under the control of the chemistry supervisor.
Although the routine functioning of the dosimetry section appeared to meet
regulatory requirements, the section would require outside assistance to
perform technical assessments of nonroutine occurrences.
A licensee
representative stated that the need for specialized training or additional
staffing would be evaluated.
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No violations or deviations were identified.
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10. ALARA Program (83728)
Licensee representatives provided the following ALARA statistics to the
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inspector:
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Total cccumulated exposure for 1985 as of June 30 was 740 man-Rem
compared to the annual goal of 892.5 man-Rem.
b.
Total volume of solid radioactive waste shipped to a disposal facility
during 1985 as of July 31 was 13,291 cubic feet compared to the annual
goal of 16,248 cubic feet.
c.
Twenty-two percent of the licensee's radiologically controlled area was
controlled as contaminated areas (26,710 of 120,354 square feet).
Licensee representatives stated that a contamination area reduction
program was in place and expected the size of the contaminated areas to
be down to approximately 20,000 square feet within several weeks.
11.
IE Information Notices (IEN) (92717)
The inspector determined that the following information notices had been
received by the licensee, reviewed for applicability, distributed to
appropriate personnel and that action, as appropriate, was taken or
scheduled.
IEN 85-06: Contamination of Breathing Air Systems
IEN 85-42:
Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent
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Dosimeter (TLD) Elements
IEN 85-46: Clarification of Several Aspects of Removable Radioactive
Surface Contamination Limits for Transport Packages
IEN 85-48:
Respirator Users Notice:
Defective Self-Contained Breathing
Apparatus Air Cylinders
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