Text

Insp Rept 50-219/87-12 on 870422-24 & 27.Violations Noted: Failure to Provide Solid Radwaste W/Less than 1% of Vol as free-standing Liquid
	ML20214S340
Person / Time
Site:	Oyster Creek
Issue date:	05/21/1987
From:	Bicehouse H, Pasciak W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20214S336	List: ML20214S334; ML20214S339; ML20214S340;
References
	50-219-87-12, NUDOCS 8706090236
	Download: ML20214S340 (9)
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-219/87-12
Docket No. 50-219
License No. OPR-11 Priority -
Category C
Licensee: GPU Nuclear Corporation
PDox 388
Forked River,_New Jersey 08731
Facility Name: Oyster Creek Nuclear _!tation
Inspection At: Forked River, New Jersey
Inspection Conducted: April 22-24a 27, 1987
Inspectors: . N g!ZO!#7
[ J 781cehouse, Radiation Specialist date
Approved by: e g. N. '
l3F
W. J N a;s,iak,
c Chief / date
Effluents Radiation Protection Section
Inspection Summary:
In_spection on April 22-24, 27, 1987 (Report No. 50-219/87_-12)
Areas Inspecte_d: Special, unannounced safety inspection of solid radioactive
waste preparation, packaging and shipping activities including: previously
identified items, management controls, quality assurance and implementation of
the program. Special emphasis was placed on reviewing a shipment of
solidified filter sludge found to contain free-standing licuid by the South
Carolina Department of Health and Environmental Control.
Results: One violation was identified: failure to provide solid radioactive
waste with less than 1% of the volume as free-standing liquid (Paragraph 6).
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Details
1. Persons Contacted
1.1 Licensee Personnel
*J. J. Barton, Deputy Director
K. T. Brown, Quality Assurance (QA) Lead Monitor
A. Erbs, Radiation Controls Technician
*S. H. Fuller, Operations QA Manager
*C, J. Halbfosteg, Manager, Plant Chemistry /Radwaste
*M. Heller, Licensing
R. V. Hurley, Group Radwaste Shipping Supervisor
B. Krechel, Radiation Controls Technician
*M. J. Slobodien, Radiological Controls Manager
*J. L. Sullivan, Jr., Plant Operations Director
*A. H. Wacha, Radwaste Shipping Supervisor
Other licenseo personnel were also contacted or interviewed.
1.2 Contractor Pe_rsonnel
F. Decker, Solidification Technician, Chem Nuclear Services, Inc.
1.3 NRC personnel
*W. H. Bateman, Senior Resident Inspector
*J. F. Wechselberger, Resident Inspector
* denotes attendance at the exit interview on April 27, 1987
2. Scope of the Inspection
This special inspection reviewed the Itcensee's solid radioactive waste
(radwaste) preparation, packaging and shipping program as implemented
by the licensee from August 1, 1985 through April 24, 1987. On Acril 15,
1987, NRC Region I was notified that licensee's shipment No. OC-2003-87
(containing approximately 6.3 curies of total activity) had been found to
contain free-standing liquid in excess of 1?4 of the volume of that ship-
ment by the South Carolina Department of Health and Environmental Control.
The circumstances surrounding this apparent violation of conditions 32.0
and 35 of South Carolina Radioactive Material License No. 97 and NRC
requirements under 10 CFR 20.311 and 10 CFR 61.56 were reviewed. In
addition a review of the licensee's radwaste preparation, packaging and
shipping program was also completed. A sample of the Itcensee's solid
radwaste shipments (including shipment No. OC-2003-87) representing
approximately 15's of the shipments mado during 1986-87 was selected
and reviewed relative to requirements in 10 CFR 20, 61 and 71, 49 CFR
170-189 and licensee Technical Specifications. The sample included
shipments of dry active wastes, resins, evaporator residues and filter
sludge materials. The licensee's actions regarding previously identified
items were also reviewed.

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3.0 Previously Identified Items
3.1 (Closed) Violation (50-219/85-25-02) - Waste Generator Quality -
Control Deficiencies
Actions described in the licensee's letter (dated October 17,1985)
regarding deficiencies in the licensee's waste generator quality '
control (QC) program were reviewed. The licensee's Operations
Quality Assurance (QA) group increased monitoring activities
covering radwaste solidification, resin dowatering and waste
classification including increased monitoring of process control
program (PCP) performance, classification computer program review
and independent verification of critical , process calculations and
steps. The actions appeared to have addressed the specific
deficiencies in the QC program as noted in NRC Inspection Report
No. 50-219/85-25. This item is closed.
J.2 (Closed) Follow-up Item (50-219/85-25-03) - Transport package
inclusion in the QA Plan Process
The licensee made changes to the Operational Quality Assurance Plan
(Licensee No.1000-PLN-7200.01) to specifically address control of
radioactive waste shipments and packages. This item is closed.
3.3 (Closed) Follow-up Item (50-219/85-25-04) - Audits of Transportation
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Activ_itiesToincludeApplicablePortionsofIDCFG0.Aipo^nTITB- ,
QA audits of the licensee's transportation activities conducted in
1985 and 1986 were reviewed to determine if applicable parts of 10
CFR 50, Appendix 0 had been applied to the review of radwaste
preparation, packaging and shipping activities. NRC Regulatory
Guide 7.10 and IE Information Notice No. 84-50 provided the basis
for the review. Audit Report Nos. S-0C-85-13 and S-0C-86-11 were
reviewed and determined to be in general agreement with the
regulatory guidance. This item is closed.
3.4 (Closed) Unresolved Item (50-219/85-25-05) - Labeling Conflicts
The licensee made rev bions to shipping procedures to ensure that
inappropriatevendorlabeling(e.g.,"00T7A"onModel14-195 casks)
would be masked by tape before shipment. In addition, the licensee
discussed the labeling conflicts with the cask vendor and wrote a
letter to the vendor as follow-up. The actions by the licensee '
appeared responsive to the problem noted in Inspection Report No. l
50-219/85-25. This item is closed,
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                      4. Management Controls

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                         4.1 Organization
                              The Itcensee's organization was briefly reviewed to determine if        L
                              clear designations of responsibilities were provided for solid
                              radwaste processing, packaging and shipping activities. Under the
                              Manager Plant Cnemistry/Radwaste, the Radwaste Shipping Supervisor      !
                              had responsibility for solid radwaste processing, packaging and
                              shipping activities. The Radwaste Shipping Group, (including Group
                              Radwaste Shipping Supervisors and Technicians) reported to the Rad-
                              waste Shipping Supervisor and implemented the program. Radiation
,                             Controls Technicians in the Radiological Controls group provided       ;
                              surveys of radiation levels and contamination for radwasto processing   I

, and shipping activities. Contracted dowatering and solidification

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                              servicos were used to process resin, filter sludge and contaminated
                              oil radwaste materials. Although the contracted services operated
                              under licensee-approved procedures, technical direction was provided
                              by an of fsite supervisor, (within the Chem Nuclear Service, Inc.
                              organization). Prior to April 15, 1987, the Solidification Techni-
                              clan and the offsite supervisor could change important solidification  i
                              process parameters (e.g., mixing speed) without approval of the licen-
                              see's solid radwaste organization. This weakness in the control of

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                              the contracted dewatering and solidification service contributed to    l

4 the problem noted with Shipment No. OC-2003-87. t

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1 Receipt inspections of transport packages and vehicles are the ! i responsibility of the QC inspectors. Operations QA provided '

l                             monitoring activities as described in paragraph 3.1.

i j 4.2 Procedures l The Itconsee's procedures for preparation, packaging and shipping i solid radwastes were reviewed relative to criteria in Technical 1 Specification 6.8, " Procedures", and regulatory requirements in 10 ! CFR 20,311,10 CFR 71 and 49 CFR 170-189. Routino procedures were

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                              reviewed to determine if instructions regarding regulatory limits

! and acceptance critoria were provided. The technical bases for i identification of radionuclides, quantification of activities,

                              determination of classification under 10 CFR 61.55 and waste form
;                             under 10 CFR 61.56 and selection of packages for shipment under 10     !
                              CFR 71 were reviewed and discussed with members of the Radwaste
                              $ hipping group. Procedures to update the computer database for
                              scaling factors used to quantifyactivities of hard-to-identify
                              radionuclidos in the various radwaste streams and to obtain
                              additional radwaste samples for gross activity changes in Reactor      t
                              Coolant System were also reviewed. No weaknestos were noted in this    i
                              review,
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, Hypothetical radwaste sample data provided by the inspector were l used to test the computer program's capability to determine waste i '

                      class under 10 CFR 61.55, determine waste form under 10 CFR 61.56
                      and specify packaging under 10 CFR 71. The test showed that the
                      computer program's algorithms accurately determined waste class,
                      provided waste form needs and selected appropriate shipping packages
                      for the test cases.
                      Vendor dewatering and solidification procedures were reviewed to
                      determine if appropriate controls and inspection holdpoints were
                      provided.       Process Control Program implementing procedures were
                      reviewed to determine the test specimens used to provide appropriate
                      scale solidification control parameters. The inspector noted that
                      Itcensee-approved vendor procedures, (e.g., Procedure 351.36,
                      " Processing Radioactive Waste Solid and Liquid Waste by CNSI Cement                              i
                      Solidification System,") had " permissive" statements allowing                                    !
                      operator discretionary changes to key operating parameters such as                                '

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                      mixer speed, number of slurry dewatering cycles, etc. The use of

I the discretionary changes in the mixing speed for Shipment No. OC-

                      2003-87 contributed to the inadequate mixing and incomplete

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                      solidification noted in that shipment.
              4.3 Traini.ng                                                                                            r
                      The training of personnel assigned to radwaste shipping activities
                      was reviewed relative to revised commitments (see NRC Inspection                                  ,
                      Report No. 50-219/87-02 regarding NRC Bulletin No. 79-19) reflecting
                      the licensee's reorganization. Training for the Group Radwaste
                      Shipping Supervisors, technicians, QC inspectors and Radiological
                      Controls Technicians was briefly reviewed. Annual inhouse and
                      offsito training programs were provided. No deviations fron. the
                      licensee's revised commitments to NRC Bulletin No. 79-19 were noted.

I 5. l

              g ujt.Lty_A, slu ra n c e/Qu a l i ty_qo njr_o 1

1 i The provisions of 10 CFR 71, Subpart H require the establishment of a I

              quality assurance (QA) program for the packaging and shipping of radio-

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              active materials. A Commission-approved QA program which satisfies the                                   l
              applicable criteria of Appendix 0 to 10 CFR 50 and which is established.

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l             maintained and executed with regard to transport packages is acceptable
              to meet the requirements of 10 CFR 71, Subpart H. The licensee elected

l to apply the currently established 10 CFR 50, Appendix 0. OA program to l the packaging and shipment of radwaste materials. ? i

              Specific quality control (0C) requirements to assure compliance with 10
              CFR 61.55 waste classification and 10 CFR 61.56 waste form requirements
              are required by 10 CFR 20.311 for radwaste generators in addition to the                                 ,
              general QC requirements of 10 CFR 50, Appendix 0. The program requires                                   !
              Judits and management review of those audits for radwaste generator                                      1
              activities,                                                                                              i
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                                                                              The implementation of QA/QC activities to the processing, preparation,
                                                                              packaging and shipment of solid radwastes was reviewed. The inspector
                                                                              noted that upgrades had been completed to the radwaste generator and
                                                                              radwaste shipping QA/QC programs (see related items in Detail 3) and site
                                                                              QA/QC organizations were responsible for implementing all applicable QA                         l
                                                                              criteria to the processing, preparation, packaging and shipment of
                                                                              radwastes including audits of the program.
                                                                              5.1 Radwaste Generator QC Program                                                              [
                                                                                    The Operations QA organization monitors radwaste processing and
                                                                                    preparation. Quality Assurance checklists and monitoring reports
                                                                                    related to shipments of dowatered resins and solidified filter                           !
                                                                                    sludge radwaste materials were reviewed. The inspector noted that
                                                                                    the monitoring activity included notification by radwaste processors                     ;
                                                                                    at key stops, independent verification of solidification and dewater-
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                                                                                     ing, independent verification of calculations used in solidifications
                                                                                    and reviews of computer generated waste classifications.
                                                                                    Licenseo audit reports (Nos. S-0C-85-13 and 5-0C-86-11) were reviewed                     !
                                                                                    for inclusion of wasto generator requirements and management review                       i
                                                                                    and resolution of findings.
                                                                                   Within the scope of these reviews, no problems were noted.                                I
                                                                             5.2 Radwas_to $hippe d ALQC Program                                                             j
                                                                                   As noted in Detail 3, the application of the licensee's QA/QC                              l
                                                                                    program to shipping activities was reviewed and appeared to meet
                                                                                    applicable NRC regulatory guidance. Implementation of the program                         ,
                                                                                    to receipt of shipping containers and liners, control of high                             '
                                                                                    integrity containers, vehicle and package inspections and review of
                                                                                    vendor activities was reviewed for selected shipments of dry active
                                                                                   wasto, dowatered resins and solidified filter sludges and evaporator                      ;
                                                                                    residues.
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                                                                                   Within the scope of this review, no problems were noted.                                   !
                                                                      6.     Implementatinn
                                                                             The implementation of the licensoo's program for processing, preparation,                       i
                                                                             packaging and shipping solid radwasto materials was reviewed rotative to                        i
                                                                             critoria in 10 CFR 20,311, 10 CFR 71, 49 CFR 172-173 and the licensee's
                                                                             Technical Specifications and procedures. Each shipment examined was                             ,
                                                                             reviewed to determine the adequacy oft                                                          ;
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                                                                                   classification under 10 CFR 20.311 and 10 CFR 61.551                                      [
                                                                                   waste form under 10 CFR 20.311 and 10 CFR 61.56;
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                                                                                    radiation and contamination measuromonts;
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                                                                                    shipping paper and radwaste manifest documentation;
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                                                                                   package marking and labeling;                                                             i
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                   -      loading and storage of packages;
                   -      conditions of appitcable Certificates of Compliance;
                   -      vehicle placarding;                                                                                                                !
                   -      instructions to drivers;
                   -      adherence to disposal site license conditions; and
                   -      nottfication to state agencies (as applicable under 10 CFR 71.97).
                   The Itcensee hadn't conducted any special radwaste shipments, (e. g.
                   Irradiated reactor components) during 1986-87. The following table
                   summarizes the licensee's radwaste shipments:
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l                                                        Dry Active                      Filter                    Evaporator                                 l
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              Year                                       Waste (DAW)                   Media                       Residues        Resins
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              1986                                       21                             7                          7               15

! 1987 (April 15) 3 3 2 2 :

                          Totals                         24                             10                         9               17                         I
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                   A total of 9 shipments (~15%) were selected for review representing each                                                                   l
                   waste stream and the 3 radwaste classes in 10 CFR 61.55. The following
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                    list contains the licenseo'sradwaste shipments reviewed:
                   Shipment No.                               Description                                                     Date

j OC-3002-87 Evaporator residue F17/87

                   0C-4009-86                                 Dewatered resin                                                 9/15/86

i) OC-2001-87 FilterSludge(media) 1/29/87

 !                 OC-3004-86                                 Evaporator residue                                              7/10/86
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                   OC-4001-87                                 Dewatered resins                                                1/12/87

i OC-4014-86 Dewatered resins 11/15/86 ! ! 0C-4015-86 Dewatered resins 12/17/86 . 1

                   OC-1022-86                                 Ory Active Waste                                                12/30/86                        i
                   OC-2003-87                                  Filter Media (" sludge")                                       4/9/87                          l

\ ! The inspector noted that the licensee maintained radwaste shipping I ! records as " stand-alone" packages, i.e., each shipment's records included I sufficient information to allow review of each of the regulatory areas ! Itsted above. ,

j Within the scope of this review, the fo11owing violation was noted: j i ' ' - 10 CFR 20.311(d)(1) requires, in part, preparation of radwastes to a

                          meet waste characteristics requirements in 10 CFR 61.56. 10 CFR
                                                                                                                                                             !

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                           61.56(a)( 3) requires radwaste containing liquid be converted into a
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                           form that contains as little free-standing and noncorrosive Itquid as

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                           is reasonable achievable, but in no case shall that 11guld exceed
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                           1.0% of the volume for waste processed to a stable form,

i Contrary to the above, Itcensee's shipment No. OC-2003-87,

 !                         (containing approximately 6.3 curies of radioactive metal oxides
                                                                                                                                                             !

i processed to a stable form with cement in a steel liner, class A } under 10 CFR 61.55 and consigned to an " Exclusive Use" shipment on [

'                          April 9, 1987), was found to contain approximately 49 gallons of                                                                  i

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     free-standing liquid in a total waste shipment volume of 177 cubic
     feet, (i.e., 1324 gallons). The free-standing liquid equalled
 ,   approximately 3.7% of the volume of the waste. Upon receipt of the
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     licensee's shipment at the Barnwell, South Carolina disposal site,
;    representatives of the burial site operator, (i.e., Chem Nuclear
!    Systems, Inc.) and the South Carolina Department of Health and

4 Environmental Control set the steel liner aside for inspection and

     testing. Holes were tapped in the liner, free standing liquid was

     drained and collected and its volume measured. On April 14, 1987,

4 the South Carolina Department of Health and Environmental Control

     informed the licensee that free standing liquid exceeding burial site

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     license conditions and State Regulations. Subsequent measurements of                  ;

i the volume of free-standinq liquid through April 22, 1987 showed a

     total volume of at least 49 gallons had been present in the liner.
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     On April 23, 1987, the South Carolina Department of Health and                         .

1 Environmental Control issued a violation to the licensee and proposed i '

     a civil penalty of $1,000.     Failure to prepare radwaste in Shipment                !
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     No. OC-2003-87 with less than 1.0', free-standing liquid constitutes a
     violation of 10 CFR 20.311 (d)(1). 50-219/87-12-01.

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The inspector reviewed the circumstances surrounding licensee's

< shipment No. OC-2003-87 to determine the apparent causes of the

     incomplete solidification. The steel liner containing the filter                       '
                                                                                             i
!    sludge radwaste materials was solidified by a contracted vendor,

l (Chem Nuclear Systems, Inc.) using a process control program dis-

l    cussed in Topical Report CNSI-2 (4313-01354-01P-A). However, several

j changes to the process had occurred. Approximately 18 months prior j to the shipment, foaming problems with evaporator residue solidifi- ! cations had led to a reduction in mixing speed from the 65-85 i rotations per minute (RPM) called for in the Topical Report (and j associated procedures) to 45 RPM. This reduction was authorized by 1 a supeevisor employed by the contracted solidification service j vendo Subsequently, the slower mixing speed was applied to filter i sludge solidifications. Filter sludge work volumes were usually 120 ;

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     cubic feet or less.    These changes were apparently made under dis-
     cretionary steps in the procedures and were used without the review
     and approval of the licensee. In November 1986, the licensee began
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l processing filter sludge radwaste materials with higher filtrate l Ioadings due to increased filter service times. Between November ! 1986 and April 1987, 4 shipments were made of liners containing l 1

     higher filtrate-loaded sludges, (Licensee Shipment Nos. 0C-2006-86,                   i
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     0C-2007-86, OC-2001-87 and OC-2002-87.       In December 1986, licensee

j Shipment No. 0C-2001-86 was set aside for further inspection at the ( i burial site but wasn't tapped to check for possible incomplete i i solidification. Review of the solidification processing of the Ifner , ! for licensee shipment No. OC 2003-87 indicated that the thermocouple t i used to measure temperature changes associated with cement curing was j '

     lost, the volume of filter sludge materials precessed was 130 cubic

i feet and mixing speeds as low as as 30 RPM were used. The latter :

i changes (i.e.,lowermixingspeedandtheincreaseinwastevolume I ; '

.

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           from 120 cubic feet to 130 cubic feet) are believed to have con-
           tributed to incomplete mixing of the cement (solidification agent)
           with the filter sludge (waste material) and subsequent incomplete
           solidification (with remaining free-standing liquid).
           The inspector reviewed the corrective actions taken by the licensee.
           On April 14, 1987, the licensee suspended solidification operations
           and radwaste shipments pending an investigation of the problem with
           shipment No. OC-2003-87. On April 15, 1987, licensee representatives
           reviewed the shipment at the disposal site. The licensee requested a
           review by the contract solidification service and recommendations
           from the contractor for corrective action. The licensee plans to
           modify all discretionary steps in solidification procedures to
           include licensee review and approval of changes. Radwaste solidi-
           fication and shipment will be resumed following these procedural
           changes and implementation of corrective actions regarding mixer
           speed and volume of waste processed in each liner. The free-standing
           liquid removed from the liner will be solidified and buried by Chem
           Nuclear Services, Inc.
  7. Exit Interview
     The inspector met with the licensee's representatives (denoted in Para-
     graph 1) at the conclusion of the inspection on April 27, 1987. The
     inspector summarized the scope of the inspection and findings. The
     inspector discussed the violation noted by the State of South Carolina
     and emphasized the need to adequately control contractor activities.
     The inspector provided a copy of the letter and inspection report issued
     by the South Carolina Department of Health and Environmental Control on
     April 23, 1987 to the licensee on April 27, 1987 since the licensee
     hadn't received his copy. No other written material was 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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ML20214S340

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