ML20151G572

From kanterella
Jump to navigation Jump to search
Insp Repts 50-334/88-09 & 50-412/88-05 on 880222-26. Violations Noted.Major Areas Inspected:Licensee Solid Radwaste & Transportation Program Including Mgt Control, Shipments of Radioactive Matls,Training & Procedures
ML20151G572
Person / Time
Site: Beaver Valley
Issue date: 04/04/1988
From: Davidson B, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151G556 List:
References
50-334-88-09, 50-334-88-9, 50-412-88-05, 50-412-88-5, NUDOCS 8804200046
Download: ML20151G572 (9)
v • d • e


See also: IR 05000334/1988009

Text

- . _ _ _ _ _ _ _ _ _ _ __

^ *

, "..

-

.

. -

'

a

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-334/88-09

50-412/88-0S

Docket No. 50-334

50-412

I License No~. OPR-66 Priority -

Category C

NPF-64

'

Licensee: Duquesne Light Company

P.O. Box 4

Shippingport, Pennsylvania 15077

Facility Name: Beaver Valley Power Station

Inspection At: Shippingport, Pennsylvania

Inspection Conducted: February 22-26, 1988

b

Inspectors: h

BaYry S.

.h I 3/

dsepRadiaionSpecialist ' date '

-Approved by: ha l'U \ n ru C/ Y P8

'

Wa~1 ter J. ak7Cntef, Effluent' '/datt

Radiation tection Section, FRSSB, DRSS i

Inspection Summary: Inspection on February 22-26, 1988

(Combined Inspection Report Nos. 50-334/88-09:50-412/88-C5)

Areas Inspected: Routine unannounced inspection of the licensee's solid

radwaste and transportation program including; management control, shipments

'

of radioactive materials, training, procedures, package selection and quality

control.

Results: Two violations of NRC requirements were identified, failure to

account for the total activity in one shipment and failure to include the -

-

radioactivity in four waste drums on shipping papers.

,

i

i  !

,

8804200046 880408 f

PDR ADOCK 05000334  !

O DCD

'

.

,

, '..

.

DETAILS

1.0 Persons Contacted

During the course of this inspection, the following personnel were

contacted or interviewed.

1.1 Licensee Personnel

  • D. Girdwood, Director Rad Operations
  • F. Lipchick, Sr. Licensing Supervisor
  • 8. Sepelak, Licensing Engineer
  • J. Sieber, Vice President, Nuclear
  • D. Szucs, Sr. Engineer, Licensing
  • J. Belfiore, Sr. QA Specialist
  • D. Roman, Supv. QA Maintenance
  • D. Hunkele, Director QA-Operations
  • J. Crockett, Sr. Manager - Nuclear Operations
  • J. Kosmal, Manager - Radiological Control
  • M. Pergar, QC Supervisor
  • W. Canan, SHPS - Radcon
  • C. Hill, ISEG
  • J. Vassello, Director - Licensing
  • W. Brady, HP Supervisor
  • A. Castagnacci, SHPS
  • D. Blair, Director, Rad Health Services

B. Haney, Instructor

M. Shaw, Instructor

R. Snowden, QC

R. Caione, QC

1.2 NRC

  • W. Pasciak, Chief, ERPS
  • D. Limroth, Froject Engineer
  • S. Pindale, RI
  • Denotes those individuals who attended the exit interview on

February 26, 1988.

2.0 Actions on Previously Identified Items

2.1 (Closed) Inspector Follow-Up Item (50-334/84-31-01)

Assign Responsibility for Radwaste Processing. The Radwaste

Coordinator is responsible for routine processing of radwaste.

Additional details, section 3. This item is closed.

2.2 (Closed) Inspector Follow-Up Item (50-334/86-05-05)

Licensee did not have procedures for QA/QC receipt inspection of

shipping casks. The licensee has implemented cask receipt

inspection surveillances. This item is closed.

+ 2

'

.

.

.

,

.

3

2.3 (C;osed) Unresolved Item (50-334/87-15-03)

Review circumstances regarding radwaste shipment to an outside

con'.ractor for further processing. This item has been upgraded to a

potential violation of NRC requirements. Details, section 5. This

item is closed.

3.0 Management Controls

3.1 Organization

The organizational structure of the licensee for management control

of solid radwaste processing, preparation, packaging and shipping

activities and oversight of contractor supplied analyses and

shipping containers / casks were reviewed. The Beaver Valley Power

Station Operations Support group has responsibilities for resin

transfer / dewatering, evaporator bottom *; solidification, and

mechanical filter radwaste processing operations. Processing and

packaging of dry active waste (DAW) is performed by the Radiological

Controls (Rad Con) staff who report tc. the Manager, Rad Cen.

The operations staff report to the Nuclear Operating Supervisor,

Opert'. ions Support, who reports to the Plant Manager. Both Managers

report to the Senior Manager, Nuclear Operations who reports to the

Vice President, Nuclear.

An in-house computer code is used to generate classification under

10 CFR 61.55, LSA, Type "A" and "B" determinations under 10 CFR 71

and reportable quantity determinations under 49 CFR 171.8.

The Site Quality Control group performs package receipt inspections

and inspections for each radwaste shipment in a surveillance

program. The Quality Assurance group performance group performs

comprehensive audits of the radwaste program. The inspector noted

the depth of knowledge of radwaste generator and transportation

requirements demonstrated by the cognizant QA auditor.

Site Administrative Procedure (SAP), Chapter 43, "Radioactive

Materials Transportation Section Administration" is an approved but

unissued procedure which addresses all the requirements of the

Transportation Program and details the functional responsibilities of

individuals and departments. A new job description of

Transportation Supervisor was created for the assignment of key

responsibility for all aspects of the Transportation Program. As

there is no individual assigned to this position, the procedure was

not issued, The inspector stated that this item would be reviewed

in a subsequent inspection (50-334/88-09-01; 50-412/88-05-01).

3.2 Procedures

The inspector reviewed selected procedures used in the preparation,

packaging, classification and shipping of the thirteen shipments,

..

,

.

4

relative to criteria in 10 CFR 20.311,10 CFR 71.5,10 CFR 71.12,

-

Technical Specification 6.8 and 10 CFR 50, Appendix B, Criterion V,

including:

  • Radeon Procedure 3.C, "Radioactive Shipment Record"
  • Radcon Procedure 3.29, "Inspection of Radioactive Material

Packaging Prior to Shipment"

  • Radcon Procedure 3.11, "Shipping Radioactive Material for

Burial - Drums"

Radcon Procedure 3.12, "Shipping Solid Radioactive Material for

Burial - Liners"

Radcon Procedure 3.32, "Radioactive Waste Shipment Manifest

Requirements"

The first two procedures were recently revised to require retention

of all records including handwritten records and double verification

sign-offs as to the number s of packages in a waste shipment, in

response to the shipment on September 8, 1987 when four more packages

were present in the shipment than accounted for in the manifest for

Shipment Number 0951.

4.0 Quality Assurance / Quality Control

The provisions of 10 CFR 71, Subpart H require the establishment of a QA

program for the packaging and transportation of radioactive materials. A

Commission approved QA program which satisfies the applicable criteria of

10 CFR 50, Appendix B 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 use their currently

established 10 CFR 50, Appendiy. B, QA program to the packaging and

shipment of radioactive materials.

Specific quality control (QC) requirements to assure compliance with

10 CFR 61.55 and 61.56 are mandated by 10 CFR 20.311 in addition to the

general QC requirements required by 10 CFR 50, Appendix B. The

implementation of QA/QC activities for the preparation, packaging and

transportation of the thirteen shipments was reviewed.

4.1 Radwaste Generator QC Program '

The licensee's performance on providing a QC program under

10 CFR 20.311(d)(3) was evaluat(d by review of dewatering and solid-

ification procedures and records related to the shipments of solidi-

fied evaporator bottoms, filter media, dewatered resins and dry

active waste (DAW). Independent determinations of waste

classification under 10 CFR 61.55 fo. one shipment of each type was

performed.

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

shipments for which classification was reviewed appeared to be

adequately classified and meeting waste form requirements. Specific

..

.

5

holdpoints related to dewatering were provided and implemented. Tne

cement feed rate requirement in the process control program was

calibrated prior to use.

4.2 Audits

Under the licensee's QA program, an audit of radwaste preparation,

packaging and shipping activities, number BV-1-87-08 was performed

on February 23-27, 1987 and included a shipment surveillance, number

RDC-0187 in March 1987. The audit and audit check list were reviewed

and found adequate. In additicn, the inspector interviewed the lead

auditor and discussed the audit and determined the knowledge of the

auditor to be commensurate with the level needed to adequately

review the transportation area.

5.0 Implementation

From October 1986 through February 1988 the licensee made thirteen (13)

shipments of radioactive waste. These shipments were reviewed against

criteria contained in:

  • 49 CFR 170-189; and
  • Station Technical Specificatiens and Procedures.

5.1 Waste Generator Requirements

The following waste generator requirements were reviewed and

discussed with the licensee:

Waste Form and Characterization under 10 CFR 20.311(d)(1) and

10 CFR 61.56;

10 CFR 61.55;

and (h); and

  • Disposal site license conditions.

Within the scope of this review the following item was noted:

accompanying radioactive waste shipments indicate as completely

as practicable the radionuclide identity and quantity and the

total radioactivity in the shipment.

. 10 CFR 20.311(c) requires, in part, certification by the waste

generator that the transported materials are praperly

described.

.

..

.

.

6

.

Contrary to these requirements, the manifest accompanying licensee

shipment number 0951 did not identify the existence and quantity of

radioactive wastes contained in four of the eighty-four drums of the

shipment. As a result, the total activity was in error. Further,

the certification which accompanied the manifest was also in error.

Failure to account for the activity in the four drums and the total

activity in the shipment constitute a violation of

10 CFR 20.311(b). Certification that shipment number 0951 was

properly described when it was not constitutes a violation of

10 CFR 20.311(c) (50-334/8S-09-02).

5.2 Procurement and Selection of Package

The licensee's selection of packages for the thirteen shipments was

reviewed relative to requirements in 49 CFR 173 and 10 CFR 71.12,

interviews with BVPS Rad Con and QC personnel, and review of

documents, procedures, and shipping records.

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

5.3 Preparation of Packages fo,r_ Shipment

The licensee's preparation of packages for shipment, pursuant to the

requirements of 49 CFR 172 and 173 and 10 CFR 71.87 was reviewed.

The licensee's performance relative to these criteria was determined

by interviews with the BVPS Rad Con staff and review of procedures,

shipping records and other documents.

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

5.4 Delivery of Packages to Carriers

The licensee's delivery of package to carriers was reviewed against

criteria in:

  • Technical Specification and procedural requirements.

The licensee's performance relative to these was evaluated by review

of shipping records and discussions with licensee personnel.

Within the scope of this review, the following violation was noted:

in accordance with 49 CFR 172, Subpart C.

49 CFR 172.203(d)(iii) requires the activity of each package in

the shipment be included in the shipping papers.

_ __ __-

- - -

r.

. ..

.

-

.

7

Contrary to these requirements, the licensee did not include the

activities contained in four of the eighty-four packages in the

shipping papers associated with shipment number 0951. Failure to

include the activities of the four packages constitutes a violation

of 10 CFR 71.5(a)(1)(vi) (50-334/88-09-03).

5.5 Shipment Number 0951, September 8, 1987

Shipment number 0951 was sent from the licensee's facility to

Chem-Nuclear's super compaction facility in Cohanan, Illinois on

September 8,1987. On October 13, 1937, Chem-Nuclear contacted the

licensee and reported (4) more drums of waste than were identified on

the shipping papers. The manifest reported 80 drums and

Chem-Nuclear reported that they processed 84 drums. A computer

check of the serial numbers for these drums indicated that they

should have been in storage for a future shipment.

As a result of this incident, the licensee notified the NRC Resident

Inspector, conducted a meeting with cognizant personnel and evaluated

consequences and initiated corrective actions. The radiological

consequence of this omission of four drums on the manifest was

determined to be minimal. The total activity was 179 microcuries

for the four drums. The total activity of the shipment was

approximately 143 millicuries. Maximum radiation levels for the

four drums was 0.03 mR/hr compared to several described drums

exhibiting radiation levels greater than 100 mR/hr contact and 5 to

7 mR/hr at one meter.

The activity present in the four drums and the radiation levels

which they exhibited were small fractions of what was present in the

remainder of the shipment. Consequently, the carrier or recipient

would have been expected to exercise adequate controls on the

shipment; no greater potential for personnel exposure or

contamination, or improper transfer of materials was expected; and

the licensee made timely notification of the incident and its poten-

tial violation of NRC requirements.

6.0 Respiratory Protection Program

Review of problems with the Chemox breathing apparatus for supplying

oxygen during entry into the Unit 1 and Unit 2 containn;ents during

subatmospheric conditions was conducted. Problems with these respirators

were identified by the licensee in containment debriefing records.

According to one licensee representative, about 5 entries of several

people each are made on an average into the containments per month. The

problems noted below represent a small fraction of the times these

respirators are used for containment entries. Based on containment

entry debriefing records, the following problems were noted during

entries since May 1937:

-

~

r

~.-...

. .

..

8

.

Date of Entry Remarks

02/20/88 4 Chemox units failed

5 canisters did not work.

02/24/88 Some canisters lasted only 10 minutes.

11/10/87 3 units aid not have an inspection sticker.

I unit did not function.

11/08/87 1 unit did not function. A crooked plunge was

identified.

10/21/87 Unit worked for 30 minute!.. After 30 minutes

the user could not get the respirator to continue

worAing properly. The wo-ker ultimately

experienced heat exhaustion and was transported  :

to a hospital.

10/02/87 Lungs. collapsed after the start of work. Worker

tried to inflate with 3 spare canisters; lungs

reinflated and soon collapsed again in each

case. Work had to be terminated.

08/28/87 Right lung did not inflate properly.

Date of Entry Remarks

08/14/87 Lungs of respirator collapsed af ter about

20 minutes of use. Could not get them

reinflated. An oxygen bottle was used for

exit. Another worker experienced respirator

problems as a lung collapsed. He was able to

get it restarted.

05/30/87 5 canisters did not f anction properly.

1 respirator malfunctioned.

05/20/87 '

2 respirators failed due to bad canisters.

Entry was terminated for one person.

05/19/87 Problems encountered with 2 respirators.

Problems include aefective respirators in a "ew cases, but in most cases,

licensee's studies indicate problems were due to improper insertion of

the canister into the respirator. Information provided to the licensee '

by the vendor indicates that secure insertien of the canister is required

'

for proper operation of the apparatus. According to licensee

representatives, improper insertion of the canister is largely due to

inexperienced personnel and difficulty of inserting the canister while  ;

wearing protective clothing, in particular, under extreme environmental

conditions present in the containment.

_ _ _ -._ _ _ _ _ _ _ , _ _ _ _

- _ - _ _ _ _ - - - _

-

- . .

4

.

9

Licensee containment entry sheets require that spare canisters are

brought into the containment. In one entry it was identified that the

entry sheet had not been checked in this area, in another entry no extra

canisters were taken. Additional attention to following entry procedures

in this area is warranted,

Licensee containment exit sheets indicate when problems are encountered

with respiratory protection devices. Typically these problems are

reviewed by the respiratory protection specialist. Frequently the review

is limited to inspection of the respirators and if no problem is found

the follow-up is terminated. The licensee representatives postulated that

the majority of these problems were due to lack of experience in inserting

the canister under containment conditions. Licensee personnel said that

consideration would be given to more extensive follow-up of problems,

particularly in providing additional instructions regarding respirator use

and canister insertion to individuals that experience problems.

The licensee is in the process of purchasing Biopack-240 respirators.

These units will alleviate the problems encountered with canister

insertion. The Chemox units will be retaine;i only for fire fighting

purposes, according to licensee representatives.

This area will be reviewed during a future inspection (50-334/88-09-04;

50-412/88-05-02).

7.0 Low Level Waste Storage Facility

!

The inspector toured and reviewed the licensee's low level waste storage

facility. The design and construction of this facility was reviewed

against NRC Generic Letter 81-38, "Storage of Low-Level Radioactive

Wastes at Power Reactor Sites" November 10, 1981, Regulatory Guide 1.143

and performed under DCP568. A safety evaluation under 10 CFR 50.59 was

performed in 1985 and submitted in 1986 to the NRC.

The inspector noted that the licensee does not store combustibles in the

facility and that ar.y liquids collected in the storage area would be

collected in a sump. The licensee stated that the sump water would be

sampled prior to release.

Within the scope of this review, no concerns were identified.

8.0 Exit Interview

The inspector met with licensee representatives (noted in Section 1.0)

at the conclusion of the inspection on February 26, 1988. The inspector

summarized the scope of the inspection and findings as described in the

inspection report.

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

licensee by the inspector,

,

, - - _ . - _ __ m y _,,7 -m_~---- _ _

. --

Retrieved from "https://kanterella.com/w/index.php?title=ML20151G572&oldid=3045392"