IR 05000254/1999007

Radiation Protection Insp Repts 50-254/99-07 & 50-265/99-07 on 990309-12.No Violations Noted.Major Areas Inspected:Solid Radwaste Processing & Control Program & Radioactive Matls Shipping Program

ML20196K909
Person / Time
Site:	Quad Cities
Issue date:	03/31/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196K903	List: IR 05000254/1999007 ML20196K900
References
50-254-99-07, 50-254-99-7, 50-265-99-07, 50-265-99-7, NUDOCS 9904080129
Download: ML20196K909 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-254;50-265 License Nos: DPR-29; DPR-30 Report Nos: 50-254/99007(DRS); 50-265/99007(DRS)

Licensee: Commonwealth Edison Company Facility: Quad Cities Nuclear Power Station Units 1 and 2 Location: 22710 206th Avenue North Cordova,IL 61242 Dates: March 9-12,1999 l

Inspector: K. Lambert, Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety 9904080129 990331 "

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EXECUTIVE SUMMARY Quad Cities Nuclear Power Station, Units 1 & 2 NRC Inspection Reports 50-254/99007; 50-265/99007 This was a routine inspection of the solid radioactive waste processing and control program and the radioactive materials shipping program. The inspection included a review of waste processing,10 CFR Part 61 sampling analysis, shipping activities, hazardous material worker training, quality assurance audits, and cMervations of shipping activitie The licensee's solid radioactive waste processing program was effective, well implemented, and was as described in the Final Safety Analysis Report and the Process Control Program. The program was technically sound, and implemented in accordance with station procedures and regulatory requirements. Radioactive waste staff were very knowledgeable regarding regulations, station procedures, and industry standards (Section R1.1).

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The radioactive mater i transportation program was technically sound and implemented in accort ra with regulatory requirements. Required shipping documentation was con ,... e, accessible, and maintained in accordance with regulatory requirements (Section R1.2).

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Station personnel demonstrated a thorough knowledge of station procedures, and Department of Transportation (DOT) and NRC requirements in that radioactive raaterial packages were effectively prepared for shipment. Radiation protection technicir.. s effectively performed radiological surveys of radioactive material shipments. Statu personnel generally prepared radioactive material shipments in accordance with appropriate procedures. Good communication between personnelinvolved in radioactive material shipping activities was evident (Section R4.1).

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The licensee's training program successfully identified those individuals involved with radioactive material transportation activities and effectively provided DOT required hazardous material worker training to those individuals (Section R5.1).

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The licensee conducted thorough audits of the radioactive waste and transportation programs. The audits were technically sound and of sufficient depth to identify deficiencies and areas where improvements could be made, and followup actions were taken or planned to address identified problems (Section R7.1).

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Report Details IV. Plant Suonort R1 Radiological Protection and Chemistry Controls R1.1 Solid Radioactive Waste Manaaement Inspection Scope (IP 86750)

The inspector reviewed the station's solid radioactive waste (radwaste) processing program as described in the Final Safety Analysis Report and the Process Control Program. The inspector's review included the generation, processing and storage of solid radwaste,10 CFR Part 61 waste classification, discussions with cognizant individuals, and tours of solid radwaste storage and processing area Observations and Findinas Solid radwaste generated at the station included waste from operations and dry active waste (DAW). Operations waste included demineralizer filter elements and resins, while DAW included metal, asbestos, irradiated equipment, and waste materials removed from the radiologically protected area (RPA).

DAW minimization steps have been in-place since 1995 and recently included the removal of most of the containers intended for disposal of non-contaminated waste generated in the RPA (i.e., " green is clean" containers). This resulted in personnel bringing items to the radiologically protected area access point so they could be surveyed and released. In addition, the Process Control Program was revised in November 1993, allowing the shipment of radwaste to an intermediary processor for

. volume reducticn of resins and filter media incineration. Previously, resins and filter media were dewetered onsite and sent directly to burial. This will further reduce the waste disposed, as ucineration results in about a 90 percent volume reduction for resins and filters. Resins and filters accounted for 58 percent of the waste disposed in 199 The station generated 50,882 cubic feet of waste in 1998 that was shipped for processing and volume reduction or disposal. This was approximately 4000 cubic feet less than that generated in 1997. Materials were processed for volume reduction by compacting radiologically contaminated asbestos and materials from the radiologically protected area, decontaminating metals, and segregating and compacting " green-is clean" materials. Processing these wastes resulted in the burial of 7,883 cubic feet of radwaste in 199 Waste stream sampling and analysis to determine scaling factors was conducted in accordance with 10 CFR Part 61, the Process Control Program, and procedure QCRP 5620-06, Rev. O,"10 CFR 61 Waste Stream Sampling and Analysis." Samples from

, waste streams were composited and analyzed annually. The inspector's review

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I determined that the scaling factors were determined consistent with the guidance contained in the NRC Branch Technical Positions on Waste Classification and Waste l Form, station procedures, and the Process Control Program. Procedures reviewed were clear, concise and technically sound and radioactive waste staff were very knowledgeable of regulations, station procedures and industry standards. The scaling factors used in 1998 were consistent with past result The inspector toured the radioactive waste processing and storage areas, including the radwaste building, laundry-tool-decon building, mausoleum, and the interim radioactive storage facility. The storage and processing areas were posted and controlled, and containers were labeled in accordance with NRC requirements and station procedure Material condition and integrity of drums and containers was good. Housekeeping was also good in processing and storage areas. Housekeeping in the laundry-tool-decon building maintenance area was improved from previous inspection Radiation exposures for radwaste activities were low and varied depending on the time spent processing waste each year. The exposure per hour worked was consistent with past years' exposures from similar processing activities. Specifically, the exposure totals were (as of February 1999):

1997 1998 1999 DAW Daily Sorting / Compacting: 5.1 rem 3.7 rem 0.4 rem Sorting / Compacting High Radiation / Contaminated Material: 1.8 rem 0.3 rem 0.8 rem The dose increase in sorting / compacting high radiation / contaminated material for 1999 ,

was attributed to the cleanup and disposal of items from the spent fuel poo Conclusions The licensee's solid radwaste processing program was effective, well implemented, and was as described in the Final Safety Analysis Report and the Process Control Progra The program was technically sound, and implemented in accordance with station procedures and regulatory requirements. Radioactive waste staff were very knowledgeable regarding regulations, station procedures, and industry standard R1.2 Radioactive Material Transportation Proaram Inspection Scope (IP 86750)

The inspector reviewed the radioactive material transportation program for compliance with NRC and Department of Transportation (DOT) requirements. The review included applicable procedures, records of past shipments, personnel training, discussions with personnel, and observations of shipping activitie l 4 j l

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.. Observations and Findinas The inspector verified that plant procedures correctly referenced DOT and NRC transportation regulations. It was noted that the procedures were generally well written and provided the appropriate amount of detail, thus providing individuals adequate guidance to perform assigned task Radioactive material shipped offsite included laundry, DAW, resins, filters, equipment, and oil samples. The station made the following radioactive material shipments in 1998 and from January 1 through March 12,1999:

Numberof Shioments 1998 1999 Radwaste to burial 26 8 DAW to processor 27 5 Landry to processor 26 3 Miscellaneous radioactive material shipments 113 20 Exempt oil samples 38 3 The shipping coordinator expected the number of 1999 shipments to be similar to the number of 1998 shipments, as the licensee was completing a several year effort to reduce the amount of radioactive material stored on the site. The shipping coordinator expected fewer shipments in 200 The inspector reviewed several shipping documents for shipments made in 1998 and 1999. Shipping documents were complete and contained the proper information regarding waste classification, physical and chemical form, volume, weight, total activ'ty, proper shipping name, transportation index, and listed the letters "RQ" if a reportable quantity of radioactive material was contained in the shipment as specified by DOT requirement The inspector also reviewed the shipping documents being prepared to ship a cask for 'l burial. The shipping documents were appropriately completed and included all required 1 information. The licensee used a second individual (independent verifier) to confirm that the shipping paperwork was properly completed, and that marking, labeling and vehicle

- placarding was appropriate. Shipping information pertinent to the hazards of the l material being shipped was brought to the control room in the event an emergency ;

involving the hazardous material occurred. The control room phone was manned 24 :

hours in accordance with DOT regulations for an emergency response telephone  ;

numbe The licensee used a vendor computer program (i.e., RADMAN) to classify waste, determine if any reportable quantity limits were present, and to generate shipping papers. When a new version of RADMAN was installed, the shipping coordinator indicated that an informal verification of the new software was performed by entering data from several previous shipments and ensuring similar results. However, the coordinator indicated that he did not document this verification. A problem identification

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form was initiated in 1998 fc,r installing a new version of the RADMAN program, without authorization from the stations computer group. Corrective action included verifying that the program was properly installed and discussing the policy requirements for installation of new or revised software with the shipping coordinato The licensee maintained current files for certificates of compliance for shipping and high integrity containers, and burial site requirements. The licensee also maintained a file with current licenses for facilities that received radioactive material from the statio Conclusions The radioactive material transportation program was technically sound and implemented consistent with regulatory requirements. Required shipping documentation was complete, accessible, and maintained in accordance with regulatory requirement R4 Staff Knowledge and Performance in Raolation Protection and Chemistry R4.1 Radioactive Waste Preparation and Transportation Activities Scope (IP 86750)

The inspector observed the loading of 14 drums into a shielded transr ortation cask and

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the preparations for shipping a T-N Ram cask with highly radioactive materials from the spent fuel poo Observations and Findinos The radiation protection technicians (RPTs) assigned to prepare the T-N Ram cask for ;

shipment reviewed the applicable procedures before performing the activitie Specifically, the RPTs reviewed procedure OCRP 5630-01, Rev. 7, " Survey of Radioactive Material Shipments." In addition, the RPTs took the procedure along for reference during the radiological survey activities. The inspector observed that the ;

RPTs performed dose rate measurements along the entire surface of the package and I at one meter from the package, and that wipes were taken on the package to check for removable contamination. Because this was an exclusive use shipment, measurements were also obtained at two meters from the package and in the cab of the transport vehicle. The RPTs documented the areas of highest measurement for each section of the package as described in the procedure. The inspector also observed that the package was appropriately labeled and marked, and that the transport vehicle was placarded in accordance with regulatory requirements. The station used a second individual to verify that the package was appropriately marked and labeled, and that the vehicle was properly placarde The inspector attended a pre-job briefing for the loading of 14 drums of high level radioactive waste into a cask. The briefing was effective in that the radwaste coordinator discussed the job steps to load the drums and radiation protection personnel discussed radiation work permit (RWP) 993002, Rev.1, requirements for

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i performing the packaging operation, incluhg that all personnel handling drums wear finger dosimetry rings. The inspector then observed the loading of these drums from a storage room in the radwaste bui! ding to a cask placed in the radwaste building truck bay. The inspector noted good communication between the radiation protection technicians, operators, and management personnel assigned to the operatio As the job progressed, one operator was required to move between the radwaste building, where he operated a hoist, to the truck bay where he disengaged the drums from a hoist after being placed on a metal skid. Due to the time required for the operator to go back and forth, a decision was made to have an RPT disengage the drums from the hoist in the truck bay. This technician was originally assigned to count the wipes taken on the bottcm of the drums, by a second technician, before they were placed on the skid. Due to the originaljob assignment, this technician was not wearing finger rings. The inspector noted, that as the skid became full, the technician had to push the drums to position them properly on the skid. The RWP required that finger rings be worn when loading and preparing radwaste shipments in the barrel storage area, among other tasks, unless otherwise directed by radiation protection management; therefore the technician failed to wear finger dosimetry in accordance with the RW This was brought to the attention of the radiation protection supervisor who was observing the operation from the radwaste building. The supervisor corrected the situation by having an individual with finger rings load the remaining drums on the skids. This incident was discussed with all the RPTs including the need to review the requirements when changing, job functions to ensure compliance. Radiation protection management reviewed the drum survey data and estimated the dose of 0.09 millirem to the technician's extremity. In addition, the finger rings of the technician perfonning the wipes on the drums were sent to an offsite processor for emergency processing. The failure to wear finger rings is an example of a procedural adherence problem, and constitutes a viointion of minor significance and is not subject to formal enforcement actio c. Conclusions Station personnel demonstrated a thorough knowledge of station procedures, and DOT and NRC requirements in that radioactive material packages were effectively prepared for shipment. Radiation protection technicians effectively pe formed radiological surveys of radioactive material shipments. Station personnel generally prepared radioactive material shipments in accordance with appropriate procedures. Good communication between personnel involved in radioactive material shipping activities was eviden .

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R5 SttY Training and Qualification in Radiation Protection and Chemistry

. R Department of Transoortation Hazardous Worker Trainina Inspection Scope (IP 86750)

The inspector reviewed the hazardous material worker training provided to those individuals involved with transportation activities. This included a review of the training outline, selected individual training records, and discussions with training personnel, Observations and Findinus The training department identified nine work groups (rivolved with the transportation of -

hazardous materials (radioactive materials) that required hazardous material worker training. The training department designed a lesson plan for each group that contained general awareness, job specific, and safety training. The inspector reviewed these lesson plans and noted that they were comprehensive in content and effectively addressed DOT requirements. Personnel interviewed by the inspector had an ecceptable understanding of the requirements. The station scheduled haGrdous material worker training every two years (required every three years by DOT). Training was conducted in July / August 1997 with retraining scheduled for the fall of 199 Successful completion of training was accomplished through written examinations. The

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radioactive material shipper, independent verifier, and individual authorized to perform truck inspactions were provided more detailed training and included training in the RADMAN software or on the job training by a subject matter expert. These individuals received training in 1998, with retraining to be performed in 200 The inspector requested training information on several individuals who were observed performing radwaste transportation activities. The training department records indicated that the workers had been trained in accordance with DOT regulation Conclusions The licensee's training program successfully identified those individuals involved with radioactive material transportation activities and provided effective DOT required hazardous material worker training to those individual R7 Quality Assurance in Radiation Protection and Chemistry Activities R7.1 Solid Radioactive Waste and TranscoiMon Audits Inspectior. Scope (IP 86750)

The inspector reviewed the results of two corporate audits and one station audit of the solid radwaste and transportation programs conducted in 1998 and 1999. The first corporate audit reviewed all Commonwealth Edison nuclear plants and concluded that Quad Cit!ss' transportation and Process Control Programs were effectively

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implemented and no deficiencies were identified. The second corporate audit was performed in February 1999, and concluded that the transportation program effectively met the regulations and that the shipping coordinator demonstrated a strong knowledge of shipping requirement i l

The station performed an intemal audit of the process control program in February .

1998. This audit concluded that the p ogram effectiveness was good, with only minor discrepancies identifie The inspector's independent review concluded that the audits were thorough and effective at iilentifying deficiencies. The identified findings were not of a significant regulatory nicture and, based on discussions with licensee personnel, were being sffectively rosolve Conclusions The licensee conducted thorough audits of the radwaste and transportation programs which were technically sound and of sufficient depth to identify deficiencies and areas where improvements could be made. Identified issues were being effectively resolve X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on March 12,1999. The licensee acknowledged the findings presented and did not identify any information discussed as proprietar :

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l PARTIAL LIST OF PERSONS CONTACTED

Licensee-E. Anderson, Radiation Protection Manager K. Bethard, Regulatory Assurance, NRC Coordinator J. Dimmette, Jr., Site Vice-President L. Pearce, Station Manager G. Powell, Radiation Protection Supervisor D. Wozniak, Engineering Manager INSPECTION PROCEDURES USED -

'IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

' Opened None Closed None Discussed

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None LIST OF ACRONYMS USED CFR Code of Federal Regulations DAW Dry Active Waste DOT- Department of Transportation DRS Division of Reactor Safety FSAR Final Safety Analysis Report IP Inspection Procedure NR Nuclear Regulatory Commission - !

PDR Publlc Document Room PlF Problem Identification Form radwaste Radioactive Weste RP Radiation Protection i RPA Radiologically Posted Area i RPT Radiation Protection Technician RWP Radiation Work Permit

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LIST OF DOCUMENTS REVIEWED .

Procedures NSP-RP 5608, Rev. O, Transfer of Radioactive Samples to the Comed CTeam Facility QCAP 1100-12, Rev.16, Procedure Use and Adherence

. QCRP 5200-05, Rev. 4, Dosimetry Usage QCRP 5620-06, Rev. O,10 CFR 61 Waste Stream Sampling and Analysis

- QCRP 5620-09, Rev. 8, Administrative Packsge Process for Radioactive Material Shipments QCRP 5620-10, Rev. O, Administrative Requirements for the RADMAN Software Program QCRP 5630-01, Rev. 7 Survey of Radioactive Material Shipments

- QCRP 5630-02,' Rev.~ 6, Controls for Packaging Radioactive Material for Shipment

. QCRP 5630-03, Rev. 6, Controls for inspecting & Loading Radioactive Material Shipments QCRP 6200-05, Rev. 8, Writing Radiation Work Permits -

QCRP 6200-06, Rev. 7, Radiation Work Permit Program l

Problem Identification Forms PIF Q1998-01140, Potential violation of DOT package dose rate limits

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PlF Q1999-00926, RWP Violation i PlF Q1998-01237, Radman Software Version 5.2 Installation l' ,

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I Audits Quality and Safety Assessment, Quad Cities Station, Audit Report QAA 04-98-01, REMP/PCP

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HP/ALARA Audit, Audit Report QAA Comed-8-02 Quaa Craes Radioactive Material / Waste Transportt.uon and Disposal Assessment,2/24-25/99 l- Miscellaneous i

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. Radwaste and Transportation Graphs 10 CFR Part 61 analysis data for 1998 and 1999 Cumulative dose data for RWPs 973003,983003,993003,973005,983005,993005,973002,

- 983002, and 993002 Hazardous Material Worker Lessons Plans RWP 993002, Revision 1 and Revision 2 Dose Calculation for RPT Loading Barrels without Finger Rings on 3/11/99 Radioactive Material Shipments: 98009, 98011, 98018, 98206, 98300, 98322, 99001, 99003, 99007,99102,99201,99304,99311,99315

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