ML20148R912

Insp Repts 50-254/97-09 & 50-265/97-09 on 970609-13. Violations Noted.Major Areas Inspected:Review of Solid Radioactive Waste Processing & Shipping Program & Liquid Radwaste & Effluent Monitoring Program

ML20148R912
Person / Time
Site:	Quad Cities
Issue date:	07/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148R869	List: ML20148R912
References
50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9707080045
Download: ML20148R912 (18)

See also: IR 05000254/1997009

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q U.S. NUCLEAR REGULATORY COMMISSION

REGION lli

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Dockets No: 50 254: 50-265

Licenses No: DPR-29; DPR-30

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Reports No: 50-254/97009(DRS); 50-265/97009(DRS)

Licensee: Commonwealth Edison Company

Facility: Quad Cities Nuclear Power Station

Units 1 and 2

Location: 22710 206th Avenue North

Cordova, IL 61242

Dates: June 9-13,1907

Inspectors: R. Paul, Senior Radiation Specialist

N. Shah, Radiation Specialist

Approved by: Gary L. Shear, Chief, Plant Support Branch 2

Division of Reactor Safety

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9707080045 970701

PDR ADOCK 05000254

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EXECUTIVE SUMMARY  :

Quad Cities Nuclear Power Plant, Units 1 and 2

j NRC Inspection Reports 50-254/97009; 50-265/97009 [

This inspection included a review of the solid radioactive waste (radwaste) processing and

shipping program, and the liquid radwaste and effluent monitoring program. Additionally,

an event where a worker was locked inside the drywell (a locked high radiation area

(LHRA)) and emergent work on the Unit 2 "B" recirculation (RR) pump seal were also  :

reviewed. l

The licensee's investigation and immediate corrective actions following an event ,

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where a worker was locked in the drywell LHRA was good. The failure of the RP

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technician to verify that all personnel had exited prior to locking the drywell was >

considered a violation of 10 CFR 20.1601(d) (Section R1.1),

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Although the Unit 2 "B" RR seal replacement occurred without mishap, the

inspectors identified a weakness in the ALARA planning. Specifically, the licensee j

did not develop contingency plans, for respiratory and protective clothing l

1 evaluations, should radiological conditions change from those analyzed (Section ,

R1.2). j

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The licensee's solid radwaste transportation program was technically sound and

implemented consistent with regulatory requirements. However, one weakness  ;

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was identified in the licensee's tracking and documentation for the amount of time

high integrity containers (HICs) were exposed to sunlight (Section R1.3). )

• The liquid monitoring program was effectively implemented and effluent monitor

operability was good. Some concerns were identified with outstanding work

requests on the liquid radwaste control panel, but these concerns were being J

addressed by the licensee (Section R1.4).

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• The licensee was effectively implementing the inspection program for infrequently  !

entered tank rooms and was addressing deficiencies found during these inspections

(Section R2.1).

• The licensee was effectively maintaining records of spills and other abnormal

events, where radioactive materici was reicased outside the radiological posted area

(RPA), as required by 10 CFR 50.75(g). However, the inspectors were concerned

that areas contaminated durirg normal reactor operation, such as the waste water

and sewage treatment outdcar sludge drying areas, were not included in these

records (Section R2.2).

• The inspectors observed good procedural adherence and management oversight

during resin transfer and routine Dry Active Waste processing. The overall

exposure for these activities was low and consistent with the increase in shipping

activities since 1995. One weakness was identified with the licensee's radiological

controls of the radwaste storage and processing areas. Additionally, some

concerns were identified with the radioactive material control and accountability in

the Dry Active Waste material building and radwaste mausoleum and with the

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control of exposure and radioactive material during resin transfers. .One concern

was identified regarding the requirements for the review of vendor procedures as

stated in the Process Control Program and in station procedures (Section R4.1).  !

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The licensee's audit of the radwaste transportation program was technically sound

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and did not identify any significant shipping events (Section 7.1).

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Report Details

IV PLANT SUPPORT

R1 Radiological Protection and Chemistry (RP&C) Controls

R1.1 Workers Locked inside Locked High Radiation Area

a. Inspection Scope (83750)

The inspectors reviewed the circumstances associated with a self-revealing event

where a reactor operator was prevented from exiting a posted and controlled

Locked High Radiation Area (LHRA). The inspection included a review of the

' licensee's investigation and a review of applicable procedures and documentation.

b. Observations and Findinas

On May 15,1997, a reactor operator entered the Unit 2 drywell (a posted and

controlled LHRA) to perform work. The operator entered through the drywell

personnel hatch (the normal access) and, prior to entry, had logged into a computer

tracking system. Because of the extent of ongoing work, three RP technicians

were assigned to the drywell. All three technicians were responsible for ensuring

LHRA controls were maintained with one technician assigned sole responsibility to

perform personnel tracking and timekeeping.

About two hours after the operator entered, all of the other workers in the drywell

had exited and had been logged out of the computer. This was recorded in the

drywell logbook by the timekeeping technician, who also noted that the operator

was still in the drywell. Shortly afterward, the lead radiation protection technician

on shift, who believed everyone had exited the drywell, received permission from

the radiation protection shift supervisor (RPSS) to secure drywell access. The

RPSS then contacted the senior drywell technician (not the one performing the

timekeeping) and informed him to lock the drywell if everyone had exited. The

senior technician then locked the drywell gate, which was subsequently verified

secure by the timekeeping technician. However, prior to locking the gate, the

timekeeping technician had not reviewed the computer log or entered the drywell to

verify that all personnel had exited. Approximately three minutes later, the operator

called the RPSS and informed him he was locked in the drywell. Subsequently, the

operator was released and logged out of the drywell. The dose rates where the

operator was waiting were less than 2 millirem per hour (mrem /hr) and his total

exposure for the day was about 19 mrem.

The root cause of the event was the failure of the timekeeping technician to verify

that all personnel had exitad the drywell prior to securing the drywell gate and,

consequently, locking the operator in the LHRA. The failure to provide an individual

an exit from the drywell LHRA is considered a violation of 10 CFR 20.1601(d)

which required that the licensee establish controls over HRA access that do not

prohibit individuals from leaving an HRA (VIO 50-254/265-97009-01).

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Immediate corrective actions taken to prevent recurrence included ensuring that no

other persons were in the drywell before it was locked down and personnel

disciplinary action. Long term corrective actions were still being developed by the

licensee.

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c. Conclusions

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The licensee's investigation and immediate corrective action following an event

where a worker was locked in the drywell LHRA was good. The failure of the

licensee to verify that all personnel had exited prior to locking the drywell, was

considered a violation of 10 CFR 1601(d).

R1.2 Emergent Work on Unit 2 "B" Reactor Recirculation Pump Seal

a. Inspection Scoce

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The inspectors observed the licensee's as-low-as-reasonably-achievable (ALARA) i

planning and controls for emergent work on the Unit 2 "B" reactor recirculation

pump seal. The seal, which had been replaced approximately one month earlier i

during the Unit 2 refueling outage, was identified to be leaking during the early i

stages of reactor vessel hydrostatic pressure testing. The inspection included a l

review of the radiation work permit (RWP) and related documentation and  ;

interviews with the ALARA and work planners,

b. Observations and Findinos

The personnel dose for this work was estimated to be about 850 mrem, consistent

with the earlier seal replacement. The inspectors noted that the licensee had

implemented effective controls for the entry, including continuous radiation

protection coverage, the use of a high efficiency particulate air filter system, and

the inclusion of lessons learned from the earlier seal replacement (primarily

consisting of scaffolding location). The job was completed without mishap and for  ;

a total exposure of about 710 mrem. i

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One weakness was identified, by the inspectors, with the licensee's ALARA

planning. Specifically, the licensee had performed an evaluation to determine

whether respiratory protection was required and the type of protective clothing (i.e. l

rubber gear) needed. Based on these evaluations, the work was performed without '

respirators and without rubber gear. However, the inspectors identified that the

licensee had not developed contingency plans if actual radiological conditions

differed from those evaluated. The inspectors were concerned that the lack of

contingency planning may result in an unplanned contamination or exposure event if

radiological conditions changed. This matter was discussed with radiation

protection management who verified radiological conditions remained within the

analysis during the work and who planned to include contingency planning in similar

future evaluations.

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c. Conclusions

Although the Unit 2 "B" reactor recirculation seal replacement occurred without

mishap, the inspectors identified a weakness in the ALARA planning. Specifically,

the licensee did not develop contingency plans, for respiratory and protective

clothing evaluations, should radiological conditions change from those analyzed.  !

R1.3 Solid Radioactive Waste (Radwaste) and Transportation Programs

a. Insoection Scope

The inspectors reviewed the licensee's solid radwaste and transportation programs

as described in the Final Safety Analysis report (FSAR) and Process Control j

Program. The review included records of past shipments (denoted below), '

interviews with applicable plant personnel, and a review of training records and

NRC guidance documents concerning radwaste shipping and transportation. The i

licensee's implementation of the following station procedures was also reviewed: I

• QCRP No. 5620-09 (Revision (Rev. 4)) " Administrative Package Process for

Radioactive Material Shipments;" .

• QCRP No. 5630-02 (Rev. 4) " Controls for Packaging Radioactive Material for l

Shipment;" i

• QCRP No. 5620 06 (Rev. O) "10 CFR 61 Waste Stream Sampling and I

Analysis;"

• QCAP No. 0610-02 (Rev. 3) " Radioactive Material Shipments;" and

• QCRP No. 5630-01 (Rev. 4) " Survey of Radioactive Material Shipments"

Additionally, the inspectors reviewed radwaste shipment Nos.96-031 (Dewatered

Condensate POWDEX Resin),96-038 (Irradiated Material from Spent Fuel Pool), 97-

009 (Torus Filters) and 97-001 (Dewatered Condensate POWDEX resin)

b. Observations and Findinas

There were no significant changes in the solid radioactive waste processing

program as described in the process control program and FSAR. Since 1995, the

licensee has taken several steps to reduce waste generation including the use of

recyclable (i.e. launderable) materials and increased worker training. However,

continued station efforts to reduce the amount of radioactive material stored onsite

has resulted in an increase in the volume and number of radwaste shipments. For

example, as of June 1997, the licensee had made 145 shipments (about 37,000

ft ) compared to 287 shipments (about 88,247 ft ) total for 1996. The licensee

expected these numbers to decline as the backlog of stored material was reduced.

The inspectors verified that the licensee maintained current copies of NRC,

Department of Transportation (DOT) and applicable burial site regulations. Licensee

personnel responsible for the transfer, packaging and transport of radwaste were

delineated in writing, were trained (within the last two years) and were

knowledgeable of the new DOT rules. These DOT requirements were also

appropriately referenced in the aforementioned procedures. In particular, the

inspectors noted that Procedure Nos. QCRP 5630-02 and QCRP 5620-09 correctly

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stated the requirements for classifying shipments as Low Specific Activity (LSA)

Types I and 11 and Surface Contaminated Objects (SCO) Types I and ll, and for the

use of system international (SI) units after April 1,1997 The licensee did not plan

to make waste shipments classified as either LSA Type til or fissile material.

The licensee used a vendor computer program (i.e. RADMAN) to classify waste,

determine if any reportable quantity (RO) limits were exceeded and to generate

shipping papers. The inspectors verified that the program database contained the

correct RO and radwaste activity limits for waste classification and, through

independent calculation, that Shipment No.96-031, had been appropriately

characterized. For the other mentioned shipments, the inspectors verified that the

shipping papers were consistent with the regulations, that SI units were used (if

applicable), and that the shipments were appropriately tracked and logged.

Additionally, the inspectors verified that valid licenses and certificates of

compliance were used for shipping casks and high integrity containers (HICs).

During this review, the inspectors identified that the licensee had been incorrectly

recording the time that HICs were exposed to sunlight. This time was tracked to

determine if a HIC had suffered potential degradation due to exposure to ultraviolet

radiation, but was not a regulatory requirement.' The licensee determined that no

HIC had received a significant amount of exposure and counseled radwaste

personnel on the tracking expectations.

Scaling factors for 10 CFR Part 61 waste characterization analyses were generated

as described in Procedure No OCRP 5620-06. This procedure contained provisions

for licensee review of scaling factor results from routine sampling and/or after

significant changes in reactor water chemistry. The inspectors' review determined

that the scaling factors were determined consistent with the guidance contained in

the NRC Branch Technical Position on waste classification and waste form and that

the scaling factors being used as of June 1997, agreed with past results.  ;

c. Conclusions i

The licensee's solid radwaste transportation program was technically sound and

implemented consistent with regulatory requirements. One weakness was

identified in the licensee's tracking and documentation for the amount of time HICs

were exposed to sunlight.

R1.4 Liquid Effluent Program

a. Inspection Scoce (84750)

The inspectors reviewed selected portions of the licensee's liquid effluent control

program inc!uding effluent results, effluent control instruments, monitor calibrations

and alarm set points, monitor operability, and several effluent discharge releases.  !

b. Observations and Findinas

There were no significant changes in the licensee's liquid effluent systems as

described in the Off-Site Dose Calculation Manual (ODCM) and the FSAR.

Quantification of liquid discharges was completed in accordance with the

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appropriate procedures, and the inspector verified that offsite doses and effluent

release monitor setpoints were calculated using ODCM methodology. As described

a the FSAR, plant liquids, including chemical waste liquids, were primarily

processed and reclaimed by the use of filters and resin beds. Liquid releases

consisted primarily of batch releases of laundry and floor drain water.

The inspectors observed work request tags on various components on the liquid

radwaste control panel, some of which were over a year old. Although none of the

components needing repair were associated with safety related systems, in some j

cases the operators had to work around the equipment to complete their work. In

two cases the repairs were required for systems that were important in preventing

radwaste tank overflows, a condition that could cause unnecessary personnel

radiation exposure during cleanup. The licensee indicated they were aware of the j

work requests and were in the process of addressing the problems.

Records of radwaste monitoring equipment availability indicated that with the

exception of the Units 1 and 2 service water monitors, all other process monitors i

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had few operability problems and good availability. The service water monitor

availability was affected by problems with the loss of domestic water (needed for

the operability of the monitors) and recent station construction modifications in the

area of the monitors. However, the inspectors verified that the licensee had

implemented the appropriate compensatory measures when these monitors were

inoperable.

c. Conclusions

The liquid monitoring program was effectively implemented and effluent monitor

operability was good. Some concerns were identified with outstanding work

requests on the liquid radwaste control panel, but these concerns were being

addressed by the licensee.

R2 Status of RP&C Facilities and Equipment

R2.1 Condition of Radwaste Tank Rooms

a. inspection Scope

The inspectors reviewed the results of the licensee's annual inspection of the

radwaste tank rooms, as required by station Procedure No. OCRP 6020-03 (Rev. 4)

" Radiological Surveys." As listed in Attachment E to this procedure, the rooms

inspected included the Units 1 and 2 reactor water cleanup (RWCU) phase

separator pump and tank rooms, and the waste sludge tank, condensate phase

separator tank and waste collector tank rooms (which included the floor drain

collector and chemical waste tanks). These tanks were all controlled as locked high

radiation areas.

b. Observations and Findinas

This inspection program was started in 1996 in response to severalindustry

findings regarding the degradation of radwaste tanks. As of June 1997, the

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licensee had made three entries into these rooms (in February 1996, September

1996 and April 1997) and had planned another entry in late M97. The tank room

condition was initially verified by persoanel entries, but later a remote robot (with a

camera attachment) was used to reduce worker exposure. The total exposure for

the above three entries was about 160 mrem.

The inspectors observed videotapes and photographs documenting the results of

these walkdowns. Most of the rooms were in good condition, although there were

some examples of poor housekeeping primarily from past jobs. However, there

were signs of corrosion and leakage in the floor drain collector tank and the

chemical waste tanks. Specifically, a small 6-8" stalactite was observed near the

bottom of the floor drain collector tank and significant through-wall corrosion was

observed on a Y-junction with the chemical waste tanks overflow and unknown

system piping (this line was not documented in plant drawings). The licensee

identified the problems during the 1996 inspections and verified, in 1997, that the

tanks' condition had not deteriorated. The licensee was developing a plan to

address the identified deficiencies.

c. Conclusions

The licensee was effectively implementing the inspection program for infrequently

entered tank rooms and was addressing deficiencies found during these inspections.

R2.2 Documentation of Past Radiological Events Per 10 CFR Part 50.75(g)

a. Inspection Scope ,

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The inspector reviewed the licensee's documentation of spills or unusual

occurrences involving the spread of contamination in or around the facility as

required by 10 CFR Part 50.75(g). The licensee's program was administered under i

station Procedure No. QCRP 6100-01 (Rev. O) "10 CFR 50.75'g) Documentation."

b. Observations and Findinas

The licensee's radiation protection group maintained an index of events (including  !

those addressed under the former 10 CFR 20.302) that required documentation

under 10 CFR 50.75(g). This index summarized the date of the occurrence, the l

associated system, the event synopsis, the contamination location and the i

resolution (i.e. if decontaminated). The supporting data for each event (such as

disposal records and isotopic sampling and analysis results) were maintained in a

separate file in the radiation protection office. As of June 1997, a total of 32 ,

events was documented with the first instance occurring in April 1974. The 1

inspectors selectively verified these entries through interviews with several

employees having a long-term association with the site and by reviewing past NRC .

inspection reports.

However, the inspectors identified that documentation for the waste water and

sewage treatment outdoor sludge drying areas was not included in the 10 CFR

50.75(g) decommissioning file. These areas had uniform, low levels of

contamination and were being controlled as satellite radiation protection areas.

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Although these areas were contaminated through normal reactor operations and not

from spills or other abnormal events, they would still be considered for cleanup

during site decommissioning. The licensee planned to evaluate these items for

inclusion into the decommissioning files.

c. Conclusions

The licensee was effectively maintaining records of spills and other unusual l

occurrences involving the spread of radioactive contamination, as required by 10

CFR 50.75(g). The licensee was considering for inclusion in the decommissioning  !

files areas contaminated during normal reactor operation, such as the waste water

and sewage treatment outdoor sludge drying areas.

R4 Staff Knowledge and Performance in Radiation Protection and Chemistry

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R4.1 Solid Radwaste Processing Activities

a. Inspection Scope

The inspectors observed the condition of the solid radwaste processing and

radioactive material storage areas including the Radwaste Mausoleum, Interim

Radwaste Storage Facility and the Radwaste, Laundry-Tool-Decon (LTD) and Dry

Active Waste buildings. During the walkdown the inspectors observed the transfer

and subsequent dewatering of resin from the max-recycle spent resin tank and

routine DAW sorting and handling activities. There were no licensee shipments

occurring during this inspection. Additionally, the inspectors interviewed workers

regarding procedural and RWP requirements, and reviewed the routine exposures

from radwaste activities since 1995 and the licensee's records of HAZMAT training

(including the lesson plans) required by 49 CFR Part 173, Subpart H.

Specific documents reviewed during this inspection included:

• RWP Nos. 974002 (Rev. 0) "Radwaste and Radioactive Material Shipping

Activities" and 973003 (Rev.1) " DAW Reduction: Sort / Compact High

Radiation / Contaminated Material;" and

• Station Procedures No. OCOP 2099-6 (Rev.11) " Transfer and Dewatering of

Max-Recycle Spent Resin Tank via "B" Transfer Header," QCAP 100-15 (rev

1) " Review and Acceptance of Contractors' and Subcontractors'

Procedures," CNSI FO-OP-033-44506 (Rev.1) " Set-Up and Operating 1

Procedure for the RDS-1000 Unit at Quad Cities," and CNSI FO-AD-002 (rev l

24) " Operating Guidelines for Use of Polyethylene High Integrity Containers." l

The CNSI procedures were vendor procedures developed by the radwaste

contractor.

b. Observations and Findinas {

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During the walkdowns, the inspectors identified continuing problems with the l

posting and labeling of radiological areas and radioactive materials, respectively, j

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, and with radiological housekeeping of work areas. Specifically, the following was I

. observed

. e in the Radwaste Mausoleum the inspectors observed a contaminated ares

boundary (i.e. rope and posting) which did not clearly delineate the affected

1 area. Although the RP group subsequently determined the area was not i

contaminated, they were not aware of this posting until notified by the

inspectors;

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e in the Radwaste Mausoleum and DAW and LTD buildings, the inspectors

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observed carts (having fixed contamination) and drums (containing l

l radioactive material) where older radioactive materiallabels had not been

! removed, which could confuse workers regarding the actual contents or

radiological conditions of the package; and )

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e in the LTD building, the inspectors observed poor radiological housekeeping

i of the mechanical and electrical maintenance work areas.~ Although this

problem was partially attributed to outage recovery activities, these areas

have been of recurring concern in previous NRC intpections.

The inspectors also questioned the adequacy of the licensee's controls over ,

! radioactive material stored in the mausoleum and DAW building. Poor control of l

stored radioactive material was one of the contributing causes identified by the

' licensee for several events where such material was found outside the RPA.

Although no regulatory violations were identified, these observations were

considered a weakness in the licensee's radiological controls of these areas. The

licensee planned to evaluate these observations and develop corrective actions.

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' Based on the work observations and personnel interviews, the inspectors concluded

that the resin transfer / dewatering and the DAW sorting / handling activities were well

conducted and that personnel were knowledgeable of procedural and RWP

requirements. In particular, the inspectors obsarved good licensee oversight of

i- contractor activities and communication between the radwaste and main control

rooms during the resin transfer. However, the inspectors did identify some

[ concerns regarding exposure and contamination control. Specifically:

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l * Step D.3 of Procedure No. OCOP 2099-66 warned operators of possible

i increased dose rates in the max-recycle rooms during the resin transfer.

l However, there were no formal controls over perst inel access to this area

i nor was radiation protection aware of this procedu.al step.

e The resin transfer line was located near the control panel for the resin

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dewatering system. Normal dose rates in this area were between 1-2

,. mrem /hr and the transfer process required that an operator be near the panel

for several hours a day for 1-3 days. The licensee had established

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compensatory actions for the transfer of RWCU resin, which raised dose

4 rates near the operator to 30-50 mrem /hr, but had not considered other resin

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transfers which could also raise dose rates. These elevated dose rates could

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result in high aggregate dose to the operator, given the time spent in the

area.

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e During interviews, licensee personnel stated that the most likely problem

- during resin dewatering was plugg?ng of the transfer hoses, and described

I the corrective actions that would be taken. However, the inspectors i

observed that this problem and the associated corrective actions were not -;

L addressed in the resin dewatering procedure (No. CNSI FO-OP-032-44506). 1

i A similar problem had resulted in a worker receiving a significant  !

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contamination, during resin transfer activities at another industry site.

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1 Additionally, the inspectors identified a discrepancy in the licensee's process for  ;

j. reviewing vendor procedures. Specifically, the process control program required '

i that vendor procedures be submitted to an onsite review prior to use. Based on

! discussions with radiation protection and radwaste operations management, this

, requirement meant a formal review by the station onsite review committee (ORC).

However, the station's procedure for reviewing vendor documents (No. OCAP

E 1100-15) did not require ORC review. The inspectors noted that the

i aforementioned vendor procedures (Nos. CNSI FO-OP-032-44506 'and FO-AD-002)

were reviewed by the ORC. The licensee planned to evaluate the discrepancy and

to determine whether vendor procedures had been appropriately reviewed for

i technical concems.

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l= Radiation exposure for radwaste activities was low and was consistent with the

increase in process'ng and shipping activities as discussed in Section R1.3.  !

j Specifically, the exposure totals were (as of June 1997): '

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) 1995 .1116 .1212 ,

DAW Sorting / Compacting: 2.00 rem 2.17 rem- 0.78 rem ,

l Radioactive material shipping: 4.37 rem 6.08 rem 1.36 rem

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!. For the 1997 data, the individual dose totals ranged from 52-460 mrem and were

j distributed among workers having average lifetime dose totals (about 2-5 rem) in

L the station laborer group. Through discussions with the workers and a review of

j station records and lesson plans, the inspectors verified that personnel involved in

radwaste shipping and transportation activities (i.e. radwaste shipment

i coordinators, station laborers and radiation protection technicians) had received

4 required DOT HAZMAT training consistent with their assigned responsibilities.

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g. c. Conclusions

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} The inspectors observed good procedural adherence and manapsment oversight

[ . during resin transfer and routine DAW processing. The overall exposure for these

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activities was low and consistent with the increase in shipping activities since

! 1995. One weakness was identified with the licensee's radiological controls of the

l. radwaste storage and processing areas. Additionally, some concerns were

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identified with the radioactive material control and accountability in the DAW

3 building and radwaste mausoleum and with the control of exposure and radioactive

4 material during resin transfers. One discrepancy was identified regarding the

j requirements for the review of vendor procedures as stated in the process control

program and in station procedures.

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R7 Quality Assurance in RP&C Activities

R7.1 Solid Radwaste and Transportation Audits

a. Insoection Scoos

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The inspectors reviewed licensee actions following several violations identified by  :

the NRC during a January 1997 inspection of the radwaste transportation and i

shipping program (Inspection Report No. 50-295/304-96021) at the Zion nuclear

station. In response to these issues, the licensee initiated PIF No. 97-1258 (dated

March 31,1997) and conducted a corporate audit (concluding on April 11,1997) )

of this program, j

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b. Observations and Findinas

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The licensee's self-assessments concluded that the shipping and transportation

program was technically sound and had not resulted in any significant shipping

events. However, there were several concerns identified regarding the accuracy of

, shipping procedures, the adequacy of HAZMAT training, the implementation of the

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10 CFR part 61 program, the use of the interim radwaste storage facility and DAW

storage buildings and the description of the shipping program pertaining to job

positions and responsibilities. For example, the auditors identified that the l

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licensee's use of the interim radwaste storage facility and DAW buildings was

inconsistent with the associated 10 CFR 50.59 safety evaluations. These

evaluations were performed with the intent to use these buildings for the extended i

storage of radwaste following the 1994 closure of the burial sites. When the burial

, site access was reinstated in 1995, the licensee shipped all previously stored

material and began using the buildings as radioactive material storage areas.

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However, the subsequent stored material was not packaged in a form ready for

shipment nor free of surface contamination as stated in the safety evaluation. The

i auditors were concerned that this practice resulted in a regulatory violation.

. The inspectors independent review concluded that the audit was thorough and

effectively addressed those areas found deficient during the above Zion inspection.

The identified findings were not of a significant regulatory nature and, based on

discussions with the licensee, were being effectively resolved. For the above

example, NRC guidance has been that a safety evaluation was not required for the

above buildings nor for the storage of radioactive materialin satellite radiation i

protection areas. Although the licensee's failure to mect the safety evaluation

requirements was not considered a violation, the inspectors agreed with the

auditors' conclusion that the failure to revise the safety evaluation was a weakness

in the management oversight of these buildings. The licensee planned to revise the

safety evaluations for the above buildings and to develop corrective actions for the

other findings.

c. Conclusions

The licensee's audit of the radwaste transportation program was technically sound

and did not identify any significant shipping events.

13

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

. .

4

R8 Miscellaneous RP&C lasues

4

The following items identified in previous inspection reports were reviewed by the

inspectors

4

'

(Closed) VIO 50-254/265 97003-01: Violation for failure to follow RP procedures.

The licensee reposted the Unit 2 "A" residual heat removal drainage trough and

1

relabeled the check sources on the service and radioactive waste affluent monitors.

-

Other, similar controls were also verified in the remaining Units 1 and 2 corner

rooms and radiological monitors, respectively. The applicable station Procedure,

i

No. OCRP 5010-1 " Radiological Posting and Labeling" was also revised to clarify

posting and labeling requirements for radioactive material. Based on these actions,

this item is closed.

X1 Exit Meeting Summary

! The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on June 13,1997. The licensee acknowledged the findings

i presented and did not identify any of the documents listed as proprietary. A partial listing

.

of those attending the exit included:

,

! P. Bherins, Chemistry Supervisor

! D. Cook, Operations Manager

E. Kraft, Station Vice-President

4 W. Lipscomb, Work Control Superintendent

l L. W. Pierce, Station Manager

a G. Powell, Radiation Protection Manager

) W. Schmidt, ALARA Supervisor

i R. G. Svaleson, RP/ Chemistry Superintendent

i

M. B. Wayland, Maintenance Manager

A. Williams, Radwaste shipment coordinator

&

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.- - _ . . .. _.-_ - . . . .. _ _ _ - . - . .

. .  !

INSPECTION PROCEDURE USED

IP 83750 OCCUPATIONAL RADIATION EXPOSURE

IP 84750 REACTOR WATER CHEMISTRY AND GASEOUS AND LIQUID EFFLUENT

RELEASE PROGRAM l

lP 86750 SOLID RADIOACTIVE WASTE AND TRANSPORTATION PROGRAM

,

i

ITEMS OPENED, CLOSED or DISCUSSED l

l

99AG i

!

VIO 50-254/265-97009-01 Individual locked inside an LHRA (Section R1.1)

l

Closed

i

VIO 50-254/265-97003-01 Failure to follow RP procedures (Section R8)

Discussed

None

1

15

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

. .

LIST OF ACRONYMS USED

[ ALARA As-Low-As-Reasonably-Achievable

RWP Radiation Work Permit

!

ODCM Offsite Dose Calculation Manual

FSAR Final Safety Analysis Report

i Rev. Revision

, DAW Dry Active Waste

i DOT U. S. Department of Transportation

LSA Low Specific Activity

I SCO Surface Contaminated Object

i SI System International

1

RO Reportable Quantity

HIC High integrity Container

3~ RWCU Reactor Water Cleanup

j LTD Laundry-Tool-Decon

.,

mrem /hr Millirem per hour

-

RP&C Radiation Protection and Chemistry

1

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2

!

,

4

1

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d

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.-. - - - -... - - _

.- - - -. - . --_ - . .

,

, . .

'

l

l LIST OF DOCUMENTS REVIEWED

NRC Waste Technical Position, Revision 1 (dated January 24,1991)  !

NRC Final Waste Classification and Waste Form Technical Position Papers (dated May 11, l

-

1983) )

l NRC Final Branch Technical Position on Concentration Averaging and Encapsulation (dated

April 12,1994) i

'

j

NRC Supplemental Guidance on the Implementation of 10 CFR part 61 (dated January 30, 1

i 1994)

,

NRC IE Bulletin No. 79-19 " Packaging of Imw-I2 vel Radioactive Waste for Transportation

and Burial" (dated August 10, 1979)

NRC Generic letter No. 95-09 (and supplements) " Monitoring and Training of Shippers and

l= Carriers of Radioactive Materials" (dated November 3,1995).

-

l

)

! Station Procedure Nos:

,

) QCRP 5620-09 (Rev. 4) Administrative Package Process for Radioactive Material

,

Shipments

.

QCRP 5630-02 (Rev. 4) Controls for Packaging Radioactive Material for

j Shipment

QCRP 5620-06 (Rev. 0) 10 CFR 61 Waste Stream Sampling and Analysis

', QCAP 0610-02 (Rev. 3) Radioactive Material Shipments

QCRP 5630-01 (Rev. 4) Survey of Radioactive Material Shipments

! QCOP 2099-6 (Rev.11) Transfer and Dewatering of Max-Recycle Spent Resin

i Tank via "B" Transfer Header i

QCAP 100-15 (Rev.1) Review and Acceptance of Contractors' and

Subcontractors' Procedures ,

QCRP 6100-01 (Rev. 0) 10 CFR 50.75(g) Documentation

4

QCRP 5010-01 (Rev. 6) Radiological Posting and Labeling

i

'

QCRP 6020-03 (Rev. 4) Radiological Surveys l

QCCP 0400-09 (Rev. 2) Fe-55, Sr-89, Sr-90, and Gaseous Alpha Release  !

Liquid Waste Worksheet  !

QCCP 0300-02 (Attachment A)

QCCP 0300-02 (Attachment B) Calculation of Liquid Waste Activity

QCCP 0300-02 (Attachment C) Calculation of Liquid Waste Activity

CNSI FO-OP-033-44506 (Rev.1) Set-Up and Operating Procedure for the RDS-1000 Unit

at Quad Cities

CNSI FO-AD-002 (Rev. 24) Operating Guidelines for Use of Polyethylene High

Integrity Containers

17

. .

Radiation Work Permits mWPs) Nos:

974002 (Rev. 0) "Radwaste and Radioactive Material Shipping Activities"

973003 (Rev.1) " DAW Reduction: Sort / Compact High Radiation / Contaminated Material"

972082 (Rev. 0) "2B Recirculation Pump: Remove / Replace / Test Seal"

PIF No. Q1997-02321 (dated 5/15/97) " Worker locked in a Locked High Radiation Area"

PIF No. 97-1258 (dated 3/31/97) Review of Radwaste Shipping Program

Corporate Audit Report No. DG-97-13/QDC (dated April 4,1997) Radioactive Waste

Management / Radioactive Material Transport and Quad Cities Station

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