IR 05000146/1997001

Insp Rept 50-146/97-01 on 970127-29.No Violations Noted. Major Areas Inspected:Procedures Development,Adherence to Procedures & Quality Assurance Oversight of Procedures

ML20140B720
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	03/18/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140B718	List: IR 05000146/1997001 ML20140B713
References
50-146-97-01, 50-146-97-1, NUDOCS 9703280130
Download: ML20140B720 (10)

Text

- -_.. _ . . .. . - _ _ - . . - . _ . - . _ - - . .-___-~..__ _ - __ - ...-. - - . - - - . . . _

.

.

1

l U.S. NUCLEAR REGULATORY COMMISSION j REGION I 1  ;

! Docket No: 50-146

License No: DPR-4

!

Report No: 50-146/97-01 i Licensee: GPU Nuclear Corporation and l Saxton Nuclear Experimental Corporation i

l Facility: Saxton Nuclear Experimental Facility i

!

Location: Saxton, PA 16678 Dates: January 27-29,1997 Inspector: Thomas F. Dregoun, Project Scientist Approved by: John R. White, Chief, Radiation Safety Branch Division of Reactor Safety 9703280130 970318 PDR ADOCK 05000146 G PDR

. - - - _

'

.

.

EXECUTIVE SUMMARY l

The policy used to create SNEC procedures was acceptable. Oversight by the Radiation l

.

Safety Committee was adequate. Programs in development for the conduct of 50.59 )

reviews, protecting workers and the public from transuranic radioactive material, and j control and monitoring of effluents appeared to be good.

.

l l

l I

i

i

!

,

II

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

.

'

!

1 Report Details i

V Summarv of Plant Status i Construction of the decommissioning support building (DSB) was complete except for fire i

and security alarm systems. An automatic frisker was operational in the DSB area that will

serve as the access control point for reactor containment. A prefab metal building with HEPA filtered exhaust was erected inside containment. It will be used to control airborne contamination and debris during cutting of scrap metal to fit through the access hatch.

O3 Operations Procedures and Documentation f

j Insoection Scope The inspector reviewed the following:

f * procedures development,

* adherence to procedures, and

equality assurance oversight of procedures, i

. Observations and Findinas

-

SNEC policy 6575-ADM-4500.07 for procedure development was issued in

November 1995 and incorporates lessons from the inadvertent penetration of the

! containment vessel shell during characterization sampling in May 1995. The policy i requires, in part, two levels of review by certified individuals, the Independent ,

'

Safety Reviewer, and the Responsible Technical Reviewer (RTR) prior to issuance of 1 a procedure. Procedures or work instructions are used to control all work at the

SNEC site. The licensee stated, in a July 27,1995, letter that this change would j prevent occurrences similar to the containment breech in the future. During this inspection, the train'ing and qualification of RTR and other engineering personnel ,

was also discusse l

'

l

In addition to these controls, a quality assurance auditor advised the inspector that i

'

,

the QA program provides a list (OCL) of activities that require a procedure in policy I

1. 1000-PLN-3000.05. TS change No. 58, submitted for NRC review on November

-

25,1996, will require QA oversight of procedures as described in proposed TS l l Section 3.6.1. Periodic QA audits, such as the one in progress during this j inspection, will verify adequacy and adherence to procedure Conclusions

>

l Development and use procedures for the control work appears to be effectiv i j

!

!

4

!

-.

.

06 Operations Organization and Administration a. inspection Scope The inspector reviewed:

• organizational changes, and estatus of commitment b. Observations and Findinas i

The vice president of the Nuclear Services Division, Dr. R. Long, retired and was replaced by Mr. A. Rone. Mr. Rone's title changed to Vice President, Nuclear ,

Safety and Technical Services. The licensee indicated that staffing levels and other I titles remained the same, l

'

The SNEC program director stated that all previous commitments made by GPU in the original Decommissioning Plan and associated submittals (now referred to as the Post Shut-Down Activities Report), and in answers to NRC questions related to ,

these documents, will remain in effect for the duration of the project. Management '

assigned responsibility to SNEC Quality Assurance to maintain a list of commitments and to conduct audits to verify implementation. The inspector noted that this was commendable and ensures continuity. The inspector stated that the ;

NRC views noncompliance with commitments to be a deviation rather than a I violation of regulatory requirement c. Conclusions Staffing satisfies TS B.1 requirement Quality Assurance in Operations )

07.1 Committees. Audits and Reviews a. Inspection Scope The inspector reviewed:

• Radiation Safety Committee agenda, and

• Committee membershi _-____-- ____ -

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

.

l .

s

' Observations and Findinas The RSC met quarterly as required by TS B.2(a). In June 1996, an environmental

'

specialist and a construction engineer were added to provide additional areas of expertise. This raised committee membership from five to seven. The breadth of

technical skills represented on the committee appeared adequate for oversight of decommissioning activitie Preparation of RSC meeting agenda topics and reporting of results to upper management were done in accordance with TS requirements. The inspector noted that a more proactive use of the RSC might be achieved by using the committee for j review of planned activities rather than after-the-fact. The SNEC program director stated that this matter would be reviewed.

, Conclusions

Review and oversight functions of the RSC satisfied requirement l i

i 08 Miscellaneous Operations issues

.  !

08.1 10 CFR 50.59 Reviews I

! Scoce i

j The inspector reviewed:

j estatus of guidance for reviews,

equalifications of reviewers, and oprocess to initiate reviews.

! Observations and Findinas i '

i The licensee stated that reviews will be conducted using NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations" prepared by NUMARC. The licensee is aware of

NRC reservations regarding portions of this document and will make appropriate

adjustments. Efforts to formalize the SNEC review process and improve

documentation were in progress and would be forwarded to the NRC ior information j when complete.

i The need for a 50.59 review is determined during processing of new procedure Reviews are completed by RTR personnel, who are trained and qualified to perform the review. They are requalified bienniall : Conclusions A policy to trigger 50.59 reviews by qualified personnel is in place. Guidance for conduct of the review is being developed.

,

, - - -- ,

.

.

l R1 Radiological Protection and Chemistry Controls l

R1.1 Control of Transuranic isotopes l Inspection Scope (Insoection Procedure 83743 The inspector reviewed the following areas:

• Worker protection for alpha emitters, l eAlpha surveys, l

• Alpha detection equipment, and l eProcedures and policies.

4 Observations and Findinas Transuranic alpha radiation emitters in parts of the reactor system will require control to limit airborne concentrations to restricted levels during system dismantlement. The licensee stated that procedures were stillin development, but management's approach was described to the inspector. The licensee's goals are to prevent worker uptakes and minimize spread. This will be accomplished by education, increased surveys, and positive control of work. Specific training regarding alpha emitters and controls was provided to the HP technicians by the RSO. Workers, support staff, and engineers will also be trained, i Laboratory monitoring equipment and techniques for alpha detection will follow generally accepted practices. Field measurements will be based on easier to detect gamma measurements. Alpha levels will be inferred from the gamma levels using ratios calculated for the isotopic mix in the area. The storage well area was found to contain a different mix relative to other areas during the characterization studies and will have its own rati Work areas will be color coded to reflect the level of alpha and beta / gamma contamination and degree of controls required to minimize internal exposures. The zone designations will be based on NRC Regulatory Guide 1.86 criteria. The level of controls will be dictated by the color cod Conclusions l

!

The elements of the proposed plan appear adequate to protect workers and the l publi l

.

.

R1.2 Effluent and Environmental Monitorina Inspection Scoce (Insoection Procedure 80745)

The inspector reviewed:

• Location and type of effluents monitors,

• Control of releases, and,

• Analysis of sample Observations and Findinas Site ground water is monitored with 8 shallow wells and two angled deep well Five of the shallow wells are down gradient and three are up gradient based on a 1994 hydrology study. Water samples are drawn quarterly from the monitoring wells, the site surface water outfall, and two potable water faucets near the sit These are analyzed for gross beta / gamma emitters and tritium at the GPU environmental laboratory. The NRC has previously reviewed the laboratory program and found it acceptabl There are 27 environmental TLDs distributed in concentric rings around the site, biased in downwind directions based on historic wind rose data. Two control TLDs are ten miles from the site. Starting in January 1997, TLDs are exchanged quarterly. The licensee indicated that the public exposure limit of 25 millirem per year is implemented as specified in EPA regulation 40 CFR 19 Effluent releases are expected to be minimal during decommissioning. The air ,

exhaust from the containment vessel during decommissioning will be monitored )

continuously with an alarm that trips the fan and sounds on-site as well as remotely. The alarm setpoint will be based on a 7 millirem TEDE population dose per quarter (15 millirem per year) calculated assuming a dispersion factor of 1E-5 for a ground level release under adverse atmospheric conditions. Grab samples downstream of the air exhaust filters will be taken weekly and analyzed for beta / gamma and alpha activity. Broad leaf vegetation adjacent to the site will be sampled during the growing seaso Release of water, if required, will be authorized by the RSO on a case-by-case basis. Aquatic sediment will be sampled quarterly at four runoff locations adjacent to the sit l Site walk-over and airborne surveys in 1993, along with soil core bores, indicated that no on-site disposal of radioactive material occurred during operations. The licensee indicated that these results would be made available for NRC revie The licensee stated that the effluent control and environmental monitoring programs will be submitted to the NRC for approval as a Radiological Environmental Technical Specification. This willinclude an Offsite Dose Calculation Manual. Documents describing these programs are currently in draf . _ - - . .. ..-. _ .. . . . . - . - . - _ _ . . . - . = -. .. . . ~ . - . . - . -

.

l l

6 Conclusions The proposed program for effluent control and environmental monitoring appeared to be goo Exit Interview (Inspection Procedure 30703)

l The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on January 29,1997. The licensee acknowledged the findings.

i I

'

!

i

!

I i

i l

l

!

!

!

!

l

I

f

. .. .

.

.

PARTIAL LIST OF PERSONS CONTACTED Licensee Perry Carmel, SNEC Site Supervisor Dave Ethridge, Safety Director, TMI William Heysek, Regulatory Affairs Robert Holmes, Engineer, DD&E Joe Kuehn,Jr., Vice President SNEC Joe Melnic, Environmental Scientist Brad Parfitt, Senior Radiological Engineer Arthur Paynter, SNEC Radiation Safety Officer ,

Lawrence Simon, SNEC Radwaste Shipping Supervisor  ;

Saxton Citizens Task Force ]

Charlie Barker, Task Force Member Roger Granlund, Independent Assessor (Penn. State RSO)

l INSPECTION PROCEDURES USED IP 30703: ENTRANCE AND EXIT INTERVIEWS IP 36XXX: ORGANIZATION, MANAGEMENT, AND COST CONTROLS AT PERMANENTLY SHUTDOWN REACTORS (DRAFT)

IP 37XXX: SAFETY REVIEWS, DESIGN CHANGES, AND MODIFICATIONS AT PERMANENTLY SHUTDOWN REACTOR IP 80745: CLASS I NON-POWER REACTOR EFFLUENT AND ENVIRONMENTAL MONITORING IP 83743: CLASS I NON-POWER REACTORS RADIATION PROTECTION INSPECTION MANUAL PART 9900: 10 CFR GUIDANCE- 10 CFR 50.59, INTERIM GUIDANCE ON THE REQUIREMENTS RELATED TO CHANGES TO FACILITIES, PROCEDURES AND TESTS (OR EXPERIMENT)

ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None

. _ _ . . _ _ . _ _ . _ _ _ . . _ . _ . _ _ . _ . . . _ . _ . _ . . . _ . . _ _ ._ .

f 1 .

l*

'

!

i l 8 .!

,' LIST OF ACRONYMS USED >

-

.

!

l CFR Code of Federal Regulations

, DD&E Decontamination and Decommissioning Engineering i GPU General Public Utilities Corporation  !

, HEPA High Efficiency Particulate Air filter l lP Inspection procedure

NRC Nuclear Regulatory Commission >

! NUMARC Nuclear Utility Management Council t QA Quality Assurance i i RSO Radiation Safety Officer i RTR Responsible Technical Reviewer j RWP Radiation Work Permit '

d TEDE Total Effective Dose Equivalent j TLD Thermoluminescent Dosimeter

+

TMl Three Mile Island power station l

.

TS Technical Specifications ,

t i I

'

!

l '

'

h

i a

$. .

i

.

!

i d

l n

,

i i

j i

i

i

!

!

!

d. . . -- . . - ..