ML20151B863
| ML20151B863 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/29/1988 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151B859 | List: |
| References | |
| 50-277-88-05, 50-277-88-5, 50-278-88-05, 50-278-88-5, NUDOCS 8804110319 | |
| Download: ML20151B863 (12) | |
See also: IR 05000277/1988005
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-277/88-05
50-278/88-05
Docket Nos.
50-277
50-278
License Nos. OPR-44
Priority
Category
C
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Licensee:
Philadelphia Electric Company
2301 Market Street
Philadelphia, Pennsylvania
19101
Facility Name:
Peach Botton Atomic Power Station
Inspection At:
Delta Pennsylvania
Inspection Conducted:
February 8-12, 1988
Inspectors:
k
77/dec 2 5', /99f
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H. J.VBicehouse Radiation Specialist
date~
Approved by:
G-
.d
3 -29- 8 8
gW. J. Pascfak, Chief
date
Effluents Radiation Protection Section
Inspection Summary:
_I_nspection on February 8-12, 1988 (Combined Report
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Nos. 50-277/88-05; 50-278/88-05)
Areas Inspected:
Routine
announced inspection of the licensee's solid
radioactive waste and ra6toactive material shipping programs including:
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previously identified items, management controls, quality assurance / quality
control, radiochemistry and implementation of the programs.
Mr. S. Maingi of
the Pennsylvania Department of Environmental Resources accompanied the
inspector on February 11-12, 1988.
Results: Apparent violations of 10 CFR 30.41(c) and Technical Specification 6.8 related to a shipment of 52 solidified oil drums to Quadrex-HPS, Inc. on
November 25, 1987 (Detail 9).
8804110319 880404
ADOCK 05000277
0
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OETAILS
1.
Persons Contacted
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During the course of this routine inspection, the following personnel were
contacted or interviewed:
1.1 Licensee Personnel
- F. H. Crosse, Radwaste Shipping Supervisor
- G. F. Daebler, Superintendent, Technical
- A. B. Donell, Quality Assurance Site Supervisor
M. Dragoo, Radwaste Projects Engineer
- J. E. Hesler, Radwaste Engineering Supervisor
- W. J. Knapp, Director, Radwaste Management Section (corporate)
- D. P. LeQuia, Superintendent, Plant Services
R. Lubaszewski, Radwaste Shipping Engineer
- J. F. Mitman, Senior Engineer, Radwaste
- D.L. Oltmans, Senior Chemist
Other licensee and contractor personnel were also contacted or
interviewed.
1.2 Pennsylvania Department of Environmental Resources
- S. Maingi, Nuclear Engineer
1.3 NRC Personnel
T. P. Johnson, Senior Resident Inspector
- L. E. Myers, Resident Inspector
"R. J. Urban, Resident Inspector
- Attended the exit interview on February 12, 1988
2.
Scope
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This routine safety inspection reviewed the licensee's solid radioactive
waste (radwaste) processing and preparation and radioactive materials
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packaging and shipping programs (as implemented by the licensee) from
October 25, 1986 through February 12, 1983.
During that period, the
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licensee averaged 22 radioactive materials shipments per month
(predominantly solid radwaste materials sent for disposal at two Agreement
State-licensed low-level waste burial sites). A total of 16 shipments
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(including 13 radwaste and 3 other radioactive material shipments) were
selected and reviewed relative to requirements in 10 CFR 71 and 49 CFR
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170-189 and, for radwaste shipments, 10 CFR 20.311, 10 CFR 61.55-56 and
the licensee's technical specifications and approved procedures.
In
addition, solid radwaste processing and preparation facilities and equip-
mant and previously identified items were reviewed.
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3.
Previous Identified Items
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3.1 (closed) Unresolved Item (50-278/85-36-01):
Fire Analysis For
Low-level Radwaste Storage Facility.
The licensee's initial safety evaluation report failed to provide an
analysis of the consequences of a fire in a storage cell at the
licensee's low-level radwaste storage facility.
Each storage cell
was designed to contain radioactive material in high integrity con-
tainers (HICs) as dewatered resin.
On December 19, 1985, following
discussions concerning the possibility of fire in the storage cells,
the licensee revised the safety evaluation to include the following:
Dewatered resin has less than 0.5% freestanding water but con-
tains about 50% by weight interlattice water;
Testing by Aerojet Energy Conversion Company (to design a resin
incinerator) has indicated that a substantial amount of supple-
mental fuel is required to burn resin because of the inter-
lattice water;
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Trder to burn, the stored resin must be subjected to an
e>.ablished fire with sufficient supplemental fuel to vaporize
the wator; and
Since the resin is stored in concrete storage cells with minimum
combustible material, supplemental fuel to support such a fire
wasn't available.
In addition, self-combustion of the resin due to chemical reactions
and hydrogen gas generation are controlled by the process and the
facility design. Based on these considerations, the licensee con-
cluded that there was little likelihood of resin involvement in a
fire providing a substantial radioactive source term for offsite
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consequences. The inspector noted that dewatered resins in polyethy-
lene HICs will not be stored in the facility in quantities approach-
ing design values unless the licensee is unable to use offsite burial
facilities. This item is closed.
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3.2 (Closed) Followup Item (50-278/85-36-02): Gas Generation In HICs
The licensee's passive vent design for the HICs was reviewed and
accepted by the South Carolina Department of Health and Enviror. mental
Control as adequate to prevent container breach during storage,
shipment and disposal. Administrative controls for the storage cells
include annual venting of any hydrogen gas generated during storage
within the cell Ventilation of the cell area continuously removes
any evolved gas preventing buildup to lower explosive limits. This
item is closed.
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3.3 (Closed) Followup Item (50-278/85-36-03):
Preops Testing
Preoperational test results for the low-level radwaste storage
facility were reviewed and approved by the Plant Operations Review
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Committee (PORC).
Test exceptions were dispositioned and/or
corrected and also reviewed by the PORC.
This item is closed.
3.4 (Closed) Followup Item (50-278/86-36-04): Operating Procedures
The licensee has developed and implemented controlled Radwaste
(RW-Series) procedures for the low-level radwaste storage facility.
This item is closed.
3.5 (Closed) Followup Item (50-277/86-21-01; 50-278/86-22-01):
Update Scaling Factors
The licensee has developed and implemented procedures to evaluate and
incorporate new scaling factors for hard-to-identify radionuclides as
additional vendor analysis reports are received.
Review indicated
that the 1986 updates to scaling factors had been included.
Discus-
sion indicated that the 1937 updates (received by the licensee in
January 1988) were being reviewed and evaluated for incorporation
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into procedures.
This item is closed.
3.6 (Closed) Violations (50-277/86-21-02; 50-278/86-22-02;
50-277/86-21-03; 50-278/86-22-03; 50-277/86-21-04; 50-278/86-22-04)
Iron-55 and Nickel-63 problems with shipment No. 45-86.
The licensee completed actions as described in the licensee's letters
dated December 31, 1986 and March 30, 1987. These actions included
re-evaluation of the activities, radionuclides and classification of
152 licensee shipments and updates to shipping and disposal records
and institution of revised procedures to prevent recurrence of the
problem. These items are closed.
4.
Management Controls
The licensee's organization, staffing, procedures and training were
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reviewed relative to licensee commitments and technical specification
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requirements.
4.1 Organization
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The organizational structure of the licensee's solid radwaste proc-
essing and preparation (including oversight of contracted dewatering
services) and radioactive materials packaging and shipping activities
was reviewed and discussed with the licensee. The inspector noted
that the station organization was undergoing substantial change.
Three related functional areas, (i.e. health physics, chemistry and
radwaste), reported through their respective senior engineers to the
Superintendent-Services. The recently formed Radwaste Organization
(under the Senior Engineer-Radwaste) consolidated waste processing,
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classification, inventory, minimization, planning and engineering
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activities and radioactive materials packaging and shipping into a
single organization. Although the licensee hadn't completed all
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aspects of the reorganization, the inspector noted that roles and
responsibilities were being defined and long-standing radwaste
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problems were being aggressively addressed by the new organization,
(e.g. a backlog of about 60,000 cubic feet of radwaste materials had
been' reduced to less than 10,000 cubic feet since August 1987).
Inter faces with other sts'; ion organizations'(e.g. health physics,
chemistry, operations and quality assurance / quality control) appeared
to be improved in definition of roles and responsibilities and to be
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better understood by the radwaste staff.
Roles of other groups,
(e.g. Reactor Engineering regarding fuel pool disposal projects), had
also been defined.
The reorganization had strengthened and clarified
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the radwaste functions relative to those groups in ways that
addressed long-standing weaknesses in control of those radwaste
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operations.
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4.2 Staffing
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The inspector reviewed staffing within the Radwaste Group and noted
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that approximately 75% of the staff (including but not limited to
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senior technical / professional staff) was supplied by contractors
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including Hydro Nuclear Services and Bechtel National, Inc.
The
long-term stability of the staff was discussed with the licensee and
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the need for continuity of program was strrissed.
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4.3- Procedures
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The licensee has been extensively revising and updating existing
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procedures and developing new procedures to support solid radwaste
and shipping activities. The new Radwaste (RW) Procedure series
include
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100 Series procedures which are administrative in nature,
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200 Series procedures which deal with processing and packaging
radioactive materials;
300 Series procedures which deal with shipments of radwaste for
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disposal;
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400 Series procedures providing instructions for shipping
non-waste radioactive material;
500 Series procedures for support functions; and
600 Series procedures covering plant radwaste system operations.
The inspector selected ten procedures for review relative to 10 CFR
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20.311, 10 CFR 61.55-56, 10 CFR 71 and 49 CFR 170-189 requirements:
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RW 110, "10 CFR 61 Compliance Program," Revision 0
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(August 1, 1987);
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RW 200, "Control of Containers," Revision 2 (January 11,1988);
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RW 260, "Operation of Resin Drying (0ewatering) System,"
Revision 3 (August 1, 1987);
RW 300, "General Requirements for Exclusive Use Radwaste
Shipments," Revision 0 (December 29,1987).
RW 330 "Radwaste Shipments to Barnwell," Revision 9
(December 29,1987);
RW 380, "Response to Lost Radwaste Shipments," Revision 0 (July,
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1987);
RW 520,
10 CFR 61 Sampling," Revision 2 (November 11,1987);
RW 540, "Movement of Radioactive & Non-Radioactive Material for
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storage at Unit 1 or LLWSF," Revision 0 (May 18,1987);
RW 320.1, "Loading and Closing the HN-100 Series 2 or 3
Radioactive waste shipping cask," Revision 1 (January 8, 1988);
and
RW 320,8 "Loading and Closing the CNSI 14-195H Radioactive Waste
Shipping Cask," Revision 1 (December 29,1987).
In addition to the procedures above, the licensee's computer programs
used to classify radwaste shipments and to select packaging were
reviewed.
Within the scope of these reviews, the following item was identified:
The licensee uses three MIDAS Fortran IV and one Lotus 1-2-3
Spreadsheet programs to calculate individual and total
radioactivities, classify radwastes, select packaging and
provide supporting calculations.
The programs are supplemented
by additional review by Radwaste technical personnel to prepare
Waste Manifests and Radioactive Shipping Records.
The MIDAS
Fortran IV programs are dated and follow nomenclature and
methods used prior to 1983 changes to 49 CFR requirements The
Spread Text program is current but misleading (e.g. 10 CFR 61.55, Table I isotopes are treated as though there are Class B
limits though Class B limits do not exist for Table I).
Discussions with the licensee indicated that the Bechtel PAKRAD
program will replace existing programs providing improved
radwaste and package selection classifications. Although errors
associated with the existing programs weren't noted to have
caused regulatory problems in the 16 shipments sampled,
implementation of the improved computer program for compliance
areas is recommended and will be reviewed during a subsequent
inspection 50-277/88-05-01; 50-278/88-05-01.
In other respects, the licensee's procedures were adequate.
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4.4 Indoctrination and Training
The indoctrination and training of personnel assigned to the Radwaste
organization were reviewed briefly relative to commitments in the
licensee's letter (dated September 28,1979) responding to NRC IE
Bulletin No. 79-19.
Five members of the licensee's staff were ques-
tiened concerning annual retraining in 1987. All five had attended
the annual retraining.
Within the scope of this review, no deviations were noted.
5.
Quality Assurance / Quality Control
The application of the licensee's quality assurance / quality control pro-
gram to solid radwaste processing and preparation and radioactive
materials packaging and shipping activities was reviewed.
5.1 Waste Generator Quality Control
Specific quality control requirements are mandated by 10 CFR 00.311
to assure compliance with 10 CFR 61.55-56.
RW series procedures were
reviewed to determine if appropriate quality control checks were
included to ensure classification of radwaste shipments under 10 CFR 61.55 and proper radwaste form under 10 CFR 61.56.
Thirteen radwaste
shipments were reviewed for implementation of the procedural
holdpoints (under current RW or previous HP0/C0 series procedures),
verification of dewatering for resin shipments and verification of
hardness for solidified oils. Audit No. AP 86-111 HPC, "PBAPS 10 CFR 61 Compliance," (November 3 through December 11,1986), was reviewed
to determine its inclusion of attributes related to 10 CFR 61.55-56
compliance, management review of the audit and resolution of findings
and recommendations. The inspector noted that the licensee had
narrowed the scope of the audit coverage to improve the technical
depth in each area of review in response to earlier comments in the
1986 NRC Inspection of this area. Appropriate inspection holdpoints
were included in procedures and witnessed by quality control
personnel suitably knowledgeable in the radwaste area for the
thirteen shipments reviewed. Audit No. AP 86-111 HPC adequately
covered attributes of 10 CFR 61.55-56 and had receivad appropriate
management review and resolution of findings.
Within the scope of this review, no violations were identified.
The
licensee was implementing an effective quality control program under
5.2 Radioactive Materials Shipper Quality Assurance / Quality Control
10 CFR 71, Subpart H requires the establishment of a quality assur-
ante program for the packaging and transportation of radioactive
materials. A commission-approved Quality Assurance Program (under 10 CFR 50, Appendix B) is acceptable provided it is estaolished,
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maintained and implemented for transport packages.
The licensee
elected to apply the established 10 CFR 50, Appendix B program to
packaging and shipping activities.
RW and HP0/C0 series procedures
(previously used) were reviewed to determine quality control
attributes verified in receipt and shipping inspections of transport
packages.
Implementation of those procedures was verified for the
sixteea radioactive materials shipments reviewed.
Under 10 CFR
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71.12, applicable items of the package's Certificate of Compliance
must be reviewed and those were verified for shipments made pursuant
to 10 CFR 71.12.
Surveillance activities of shipping procedures were
also reviewed. Audit No. AP 86-02 HPC, "PBAPS Radioactive
Waste / Material Storage, Handling and Shipping," was reviewed for
inclusion of attr;butes needed to ensure compliance with 10 CFR 71.
The inspector noted that the audit team members were technically
qualified in radioactive materials shipping requirements.
Within the scope of this review, no violations were noted. The
licensee had applied applicable portions of the Commission-approved
10 CFR 50, Appendix B program to shipping activities.
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Under Technical Specification 3/4.8, the licensee is reouired to have
a Process Control Program (PCP). Under the PCP, solid radwaste
sampling and testing requirements are established.
The licensee's
application of the PCP to centrifuge dewatering, oil solidification
and vendor dewatering operations was reviewed and discussed with the
Radwaste Engineering Supervisor and a member of his staff. The bases
for the program in each area was reviewed and appropriate
implementation was verified for the radwaste shipments reviewed.
Within the scope of this review, no violations were noted.
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licensee had provided an effective PCP for each of the radwaste
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processes reviewed.
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6.
Radiochemistry
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The "Low-level Waste Licensing Branch Technical Position on Radioactive
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Waste Classification," (May, 1983, Revision 0), suggests an acceptable
sampling and analysis program for power reactors to meet 10 CFR 61.55
Waste Classification requirements for hard-to-identify radionuclides and
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allows the use of scaling or correlating factors to gamma-emitting radio-
nuclides.
Licensee fuel performance and reactor coolant system
radioactivities were reviewed to determine the general adequacy of the
licensee's sampling and vendor analysis program for hard-to-identify
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radionuclides.
The licensee had generat=d and shippod Class A and Class B
solid radwastes and had sampled the radwaste streams in 1986 and 1987.
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Review of radiochemistry data showed that substantial changes in fission
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product and activation product concentrations had not occurred without
subsequent sampling and revision of scaling factors.
Radiochemical data
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sufficient to characterize new radwaste processes had been provided.
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Within the scope of this review, the licensee was meeting suggested
sampling and analysis frequencies.
7.
Solid Radwaste Processing / Preparation
The licensee collects, processes, temporarily stores and prepares dry
active waste, def onizer resins, oils and radioactive hardware for offsite
disposal at Agreement State-licensed disposal sites.
Considerable change
had occurred since the last inspection:
In July 1987, the licensee switched from use of 55 gallon
polyethylene HICs to much larger HICs for wet wastes;
Vendor-supplied dewatering services were used for the larger HICs in
place of the installed centrifugation system in the Radwaste
Building;
Modifications were under way to install the azeotrophic distillation
and polyester solidification process known as AZTEC for operation in
1939;
Increasing use of the low-level radwaste storage facility
necessitated intrasite shipment of dewatered large HICs and dry
active waste; and
Radwaste shipments were made to an offsite vendor for
decontamination / recycle and repackaging / disposal operations.
In addition, the licensee was conducting a campaign to characterize,
prepare for shipment and dispose of accumulated solid radwaste (some
of which had been onsite since 1983). Future planning includes
vendor-supplied solidification of decontamination resins used in the
Unit 3 pipe replacement project and additional disposal of activated
components stored in the fuel pools.
The changes to radwaste processing operations which involved modifi-
cations to existing plant equipment were reviewed relative to
requirements in 10 CFR 50.59 and concensus standards provided in
ANSI /ANS 55.1 - 1979, "American National Standard for Solid
Radioactive Waste Processing Systems for Light Water Cooled Reactor
Plants."
7.1 Modification No. 1750A
This modification provided interface piping and an enclosure building
to support operation of a resin dewatering system behind the Unit 2
Reactor Building. The dewatering process include / v eping a resin
slurry into a large HIC and using an air-driven y sum pump to
extract free-standing liquid.
The inspector toured the operation,
reviewed procedures and valve alignments and examined the safety
evaluation prepared by the licensee to support the modification. The
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safety evaluation was reviewed and approved by the PORC (Meeting No.
87-70) under 10 CFR 50.59 and station technical specifications.
Within the scope of this review, no violations were noted.
7.2 AZTEC
General Electric Company developed a volume reduction and radwaste
solidification system which uses an azeotrophic distillation
mechanism (to remove water from wet waste) and a polyester
solidification process (to provide a suitable waste form). The process has
been reviewed and accepted by the NRC and the States of South
Carolina and Washington.
Since the modification to use this process
was incomplete, the process control aspet:s of the system and the
disposal of toluene were discussed with the licensee.
The review of
the licensee's modification to house the operation, safety review and
licensing requirements and normal operation were postponed pending a
licensee decision on use of the process.
7.3 Low Level Radwaste Storage Facility
The switch from 55 gallon HICs to larger HICs allowed the licensee to
use a transfer cask for dewatering and intrasite transfer of the
resulting dewatered resins.
Final preparations for shipment could he
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conducted at the licensee's low level radwaste storage facility. On
February 10, 1983, the inspector toured the facility and observed a
transfer of a dewatered HIC from the transfer cask to a shipping cask
in the facility's truck bay area.
NU problems were noted during this
review.
The inspector reviewed licensee records for radioactive material
inventory in the facility and noted that stored inventory was well
within the facility's design capacity and waste form / packaging were
also suitable for the facility.
The total inventory stored in the
facility amounted to approximately 146 curies.
7.4 Unit 3 Turbine Storage Area
On February 10, 1988, the inspector and the Senior Resident Inspector
toured the locked high radiation area at the Unit 3 Turbine deck.
The area contained approximately 185 drums (about 1300 cubic feet) of
stored radioactive materials. Radiation readings associated with the
drums ranged from about 40 millirems per hour to about 60 rems / hour
contact.
The licensee had set up a tent and temporary shield wall to
process each drum for eventual disposal.
Discussions with the
licensee indicated that the licensee planned to characterize, process
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and ship for disposal as much of the radwaste as possible.
However,
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many of the drums contained radioactive materials for which the
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licensee had little information necessitating examination and
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pr(paration activities. The inspector noted that some of the drums
had been onsite since about 1983 and had been stored previously in
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the Unit 2 Turbine locked high radiation area. Although the licensee
was making a considerable effort to reduce radwaste volume stored
onsite, the lack of necessary information on the drums in storage was
hampering the effort.
8.
Radwaste Generator Requirements
The inspector reviewed thirteen radwaste shipments made by the licensee
against each of the following radwaste generator requirements:
Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);
Waste Classification under 10 CFR 10.311(d)(3) and 10 CFR 61.55;
Waste Form and Characterization under 10 CFR 20.311(d)(3) and 10 CFR 61.56;
Waste shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR 61.55;
Tracking of raddaste shipments under 10 CFR 20.311(d), (e), (f) and
(h); and
Adherence to disposal site license conditions for Agreement State
licenses under 10 CFR 30.41.
The basis for determination of waste class, (e.g. sampling, vendor
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analyses, scaling factors for hard-to-identify radionuclides and
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calculations) was also reviewed for each shipment. The basis for
concluding that a suitable waste form was provided was also reviewed for
each shipment of dewatered or solidified radwaste materials.
Within the scope of this review, no violations were noted. Adequate
technical bases were noted for Class A and B routine shipments.
The
licensee had taken appropriate samples, updated scaling factors using
accepted methods and implemented the classification program consistent
with NRC regulatory guidance.
The process control program, routine tests
of process parameters and process quality control inspection holdpoints
were implemented for the thirteen shipments.
9.
Radioactive Materials Shipping Requirements
Sixteen radioactive material shipments
(i.e. thirteen solid radwaste and
three other radioactive materials shipments to other licensees), were
reviewed relative to criteria provided in 10 CFR 71 and 49 CFR 170-149 to
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determine if transportation requirements had been met. General
requirements for transfer of radioactive materials under 10 CFR 30,41, 10
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CFR 40.51 and 10 CFR 70.42 and adherence to licensee procedures under
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Technical Specification 6.8 were also reviewed.
Performance relative to
these criteria was determined by:
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review of procedures, procurement documents, certificates of
compliance and radioactive shipping records;
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interviews and discussions with licensee personnel concerning
shipment prepar.cion, placarding, radiation / contamination survey
techniques, labeling, securing shipments and other matters; and
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direct observation of licensee's shipment No. 12-88 made on February
10, 1988.
Within the scope of this review, the following violation was identified:
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10 CFR 30.41(c) requires, in part, that each licensee transferring
byproduct material verify that the recipient's license authorizes
receipt of the type, form and quantity of the byproduct material to
be transferred. Technical Specification 6.8 requires, in part, that
procedures be implemented.
Licensee's Procedure HP0/C0-17 requires
verification of the recipient's license prior to transfer.
Contrary to these requirements, on or about November 25, 1987, the
licensee transferred 52 solidified drums of waste oil (as shioment
No. 82-87) containing an estimated 53.51 millicuries of tritium to
Quadrex-HPS, Inc. in Oak Ridge, Tennessee.
The Tennessee Radioactive
Material License, (Number R-01037-L7), did not authorize the recipient
to possess tritium in the form of solidified oil at that time.
Amendment 38 to that Tennessee Radioactive Material License
authorized receipt of the drums for repackaging and subsequent
disposal on December 8, 1987 and was issued as a temporary amendment
(to expire on January 8, 1988) to allow receipt of the licensee's
shipment.
Subsequent recalculation by the licensee reduced the
estimated tritium content of the shipment to 0.25 millicuries and a
revised radioactive shipping record was sent to Quadrex-HPS, Inc. on
December 1. 1987. However, the licensee failed to verify that the
recinient could receive tritium contained in oil solidified in
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Environstone prior to shipping on November 25, 1987.
That failure
constitutes a violation of 10 CFR 30.41(c) and Technical Specification 6.8.
(50-277/88-05-02; 50-278/88-05-02)
10.
Exit Interview
The inspector met with the licensee's representatives (denoted in Detail
1) at the conclusion of the inspection on February 12, 1988.
The
inspector summarized the scope and findings of the inspection as described
in this report.
At no time during the inspection was written material provided to the
licensee by the inspector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.
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