IR 05000146/1987001

Insp Rept 50-146/87-01 on 870721-22.No Violations Noted. Major Areas Inspected:Preparations for Upcoming Decontamination Activities & Familiarization W/Site Layout, Personnel,Licensing Issues & Site Activities Assessment

ML20235E647
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	09/18/1987
From:	Conte R, Markley M, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235E620	List: IR 05000146/1987001 ML20235E618
References
50-146-87-01, 50-146-87-1, NUDOCS 8709280211
Download: ML20235E647 (7)

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j U.S. NUCLEAR REGULATORY COMMISSION

REGION I

. Report N /87-01 Docket N /87-01 License No. DRP-4 Priority -

Category 0 Licensee: Saxton Nuclear Experimental Corpoi= tion /GPU Corporation 1 Upper Pond Road Parsippany, New Jersey 07054 Facility Name: Saxton Reactor Inspection At: Saxton, PA and TMI Nuclear Station, Harrisburg, PA Inspection Conducted: July 21 - 22, 1987 Inspectors: bb d -

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Ay Weadock, Radiation Specialfit ' ' date

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L Av.aa - 0.nw M. arkley, Radiation Specialist # f 9 h7 /V?

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_./ Conte, Sen16r Resident Inspecif& , TMI-1 ._WJ7N7 dats j

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Approved by: g . m I M. Shanbaks Chd[ FaYil'1xTes Radiation 4//

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Protection Section, EPRPB Inspection Summary: Inspection on July 21-22, 1987 (Report No. 50-146/87-01).

Areas Inspected: Routine, announced inspection by two region-based i radiation-specialists to review licensee preparations for the upcoming '

decontamination activities. A representative from Reactor Projects Section 1A was also on-site for familiarization with site layout, personnel, licensing issues, and to assess site activitie Results: Within the scope of the above reviews, no violations were identifie l 8709280211 870918 gDR ADOCK O y6 i

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Details 1.0 Persons Contacted 1.1 Licensee Representatives J. Auger -

PWR Licensing Engineer G. Baker -

Saxton General Manager W. Craft III -

Saxton Radiation Safety Officer J. Ga rry, J Saxton Site Supervisor, GPU R. Heward, Jr. - President, Saxton Nuclear Experimental Corporation (SNEC)

R. McGoey -

Manager of Licensing - PWR M. Roche -

Vice-President, SNEC P. Schaale -

Site Coordinator (NSSI)

1.2 NRC Representatives R. Conte -

Sr. Resident Inspector, TMI-1 M. Markley -

Radiation Specialist, Region I A. Weadock -

Radiation Specialist, Region I 2.0 Purpose The purpose of this inspection was two-fold:

1) To review licensee preparations for the planned decontamination of the RWDF. Specific areas reviewed included:

a radiological surveys, e

facilities and equipment,

• procedures,

training of personne ) To provide on-site familiarization for the accompanying representa-tive from the Region I Division of Reactor Project i 3.0 Effluent Releases

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From December 8,1986 to January 8,1987, the licensee pumped thirty-five batches of infiltrated groundwater from the pipe tunnel and Radioactive Waste Disposal Facility (RWDF) basement to the Juniata River. Approximately 205,000 gallons of water were discharged. Results of radiological analyses performed by the licensee during discharge, as reported in the 1986 Saxton Operating Report, indicate that no discharges in excess of NRC discharge limits took place. Specifically, concentrations of Cs-137 and H-3 (the i predominant isotopes) discharged averaged less than 1% of the applicable i limit (10 CFR 20 App. B Table II valve). The licensee provided a composited l discharge water sample to the NRC, independent analysis of this sample l

yielded comparable result l l

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4.0 Radiological Surveys Subsequent to the pumping and discharge activities discussed in sectica 3.0, the licensee made initial entry to and survey of the lower elevations of the RWDF building. The inspector reviewed documented surveys of this entry, completed on January 13-15, 198 Surveys were noted to be extensive and clearly indicated any identified areas of loose or fixed contamination. Low levels of fixed contamination were noted throughout the lower elevation of the building; loose contamination (up to 140,000 dpm/100 cm 2 ) was noted in one area only, on a section of wall in the Evaporator Process Roo The inspector also reviewed selected surveys performed in the Control and Auxiliary (CAB) building on July 16-17, 1987. Low levels of loose contamination were identified in portions of the ventilation system ducting and in two floor mounted air-recirculating heaters. These components were appropriately posted and were excluded from work activities pending decontaminatio All surveys of the RWDF and CAB buildings reviewed above were noted to be performed with calibrated instruments and had received supervisory review. License performance and documentation of radiological surveys to support decontamination activities will continue to be reviewed during subsequent inspection .0 Facilities and Equipment During the inspection the licensee was establishing a control point in the RWDF building to support decontamination activities. Other accesses to the RWDF lower levels were being posted to insure all access to the work areas was through the control point. Supplies of respirators, protective clothing, and contamination monitoring equipment at the control point appeared sufficien The inspector also reviewed the licensee's supply of portable survey and laboratory counting instruments. No deficiencies were noted. Adequate instrumentation is on-site to support work activitie Licensee personnel i expressed the intent of adding gamma spectroscopy equipment to enhance their analytical capabilitie The inspector evaluated decontamination equipment including a newly acquired vacuum sandblaster, which will be used primarily to remove fixed contamination in the RWDF building. This was considered a good initiative which may relieve the use of respirators for some decontamination effort <

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6.0 Procedures The licensee's Technical Specifications require that radiation protection activities be performed in accordance with procedures and instructions that conform to the requirements of the Saxton Radiation Protection Manua The inspector reviewed selected procedures contained in the SNEC Radiation Protection Plan and Procedures Manual, including the following:

• 9400-PLN-4542.01 SNEC Radiation Protection Plan,

• 9400-ADM-4500.10 Surface Contamination Surveys,

• 9400-ADM-4500.14 Establishing and Posting Areas,

• 9400-4500.20 Radiation Work Permits, a 9400-ADM-4500.09 NRC Reportable Occurrences,

• 9400-ADM-4500.11 Radiation Surveys,

• 9400-ADM-4500.16 Air Sample Analysis,

• 9400-0PS-4524.12 Operation of the Ludlum Portable Scaler, Model 2000,

9400-QAP-4220.01 QA Program for Radiation Instrument The inspector noted that the majority of Saxton procedures were produced by drawing from and revising TMI-1 procedures. The inspectors noted that,

! overall, this practice has resulted in a body of procedures that appears adequate to insure SNEC radiological activities are well-controlled.

l However, specific concerns were noted with several SNEC procedures and are given belo *

The SNEC Radiation Protection Plan, Article 5, implies that only High

Radiation Areas (HRAs) above 1000 mrem /hr are required to be locked; l

HRAs between 100-1000 mreu/hr are only required to be barricaded and poste Although the above exception to 10 CFR 20.203(c)(2) is common to commercial power reactors, and is in fact contained in the TMI-1 Technical Specifications (TS), the Saxton TS contains no exemptions f concerning HRAs. Consequently, all HRAs (any accessible areas where an individual could receive greater than 100 millrem in one hour) are subject to the control requirements of 10 CFR 20.203(c)(2),

instead of just those greater than 1000 millirem /hr. The inspector noted that this appeared to be a procedural concern only. The only HRA on site was located in the reactor building and was maintained locke _ _ _ - _ _

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TMI-1 procedures referenced in SNEC procedures were not available on-sit The licensee committed to revising the SNEC Radiation Plan to insure that HRA control requirements would parallel requirements contained in 10 CFR 20. The licensee also stated that TMI-1 procedures referenced in the Saxton procedures would be made available on-sit These items will be reviewed in a subsequent inspectio * Weaknesses were noted in some procedures, apparently due to heavy editin For example, procedure 9400-ADM-4500.16 includes an internal cross-reference to the Responsibilities section of the procedur No such section, however, existed in the procedur The licensee indicated that the majority of the Saxton procedures were first or second revisions, and were still being field-tested and revised accordingly. The licensee acknowledged that similar concerns about procedure referencing, etc. had been identified during an Operations-QA audit of the Saxton site and these concerns were being addresse The inspector had no further questions in this are .0 Training The inspector reviewed current manpower staffing which included one GPU oversight person, a contractor site coordinator, three ANSI qualified HP technicians, five radiological decontamination technicians, and two mechanical decontamination technicians. All Saxton personnel received training at TMI. Discussions with HP technicians indicated adequate technical knowledge of radiological assessment and equipment operatio The inspector examined records at TMI to verify that General Employee Training, respiratory protection training, whole body counting, and medical examination requirements were me No violations were identifie .0 Site Activities Review 8.1 Background / Scope of Review By an internal realignment in the spring of 1987, Reactor Projects Section (RPS) No. lA, NRC Region I, became the project section responsible for inspection-related activities of the Saxton Nuclear Experimental Corporation (SNEC) for work at the station (SNEC).

The senior resident inspector for TMI-1, representing RPS No. IA, participated in this inspection to:

• obtain a familiarization with the site and management personnel assigned to SNEC;

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assess current activities in relation to the overall decommission plans for the site;

• take photographs of the site and facilities to be available to NRC Region I for future references; and,

• become familiar with any technical and licensing issues related to decommissionin .2 Material Conditions The primary buildings of interest are: the Containment, the Control and Auxiliary Building (CAB), and the Radioactive Waste Disposal Facility (RWDF). An empty refueling water storage tank is also located on-site, along with a temporary office traile The facility is normally not manned, but it is kept locked with an alarm security system monitored by PENELEC, a subsidiary company of GPU (General Public Utilities).

The Containment remains essentially intact, with little equipment removed; all nuclear fuel materials were removed during initial deactivation. The inspector toured the non-contaminated operating floor and observed no adverse radiological or housekeeping condition There are no immediate (1987) plans to decontaminate / dismantle the Containment. The licensee has petitioned the Pennsylvania Public Utility Commission (PUC) for the release of funds to support other site decommissioning wor The licensee reported that there is some evidence of corrosion on the 11/16-inch carbon steel containment liner. A corrosion study is being reviewed by Technical Functions Division, GPU Nuclear Corpora-tio The licensee previously committed to provide that report to the NR The RWDF building was essentially comprised only of the structural walls and flooring; all internal equipment was removed during initial SNEC deactivation. The CAB still contains ventilation ducting and electrical panels. Radiological conditions for both buildings are discussed in Section Decontamination activities planned for 1987 include removal of any loose contamination in the CAB ventilation or in the RWDF by tradi- ;

tional methods; fixed contamination, primarily located in the RWDF, 1 will be removed with the aid of a vacuum sandblaste In the meantime, the licensee will shortly be sending a Technical Specification Change Request (TSCR) to the NRC to remove these outbuildings from the surveillance requirements of the Technical

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Specifications.

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The next licensee quarterly inspection of all facility buildings is due September 1987.

l The licensee plans to have Quality Assurance (QA) monitoring of SNEC l activities from TMI-1 QA departmen No conditions adverse to nuclear or radiation safety were note .3 Licensing Issues l The Saxton Decommissioning Plan, submitted in the early 1970's, was L approved by the NRC staff in 1975. The inspector noted frequent

! reference by the licensee to Regulatory Guide (RG) 1.86 concerning site release criteria. This RG post-dates the approval documents noted above. The licensee representatives stated that RG 1.86 is l

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referenced in their Radiation Protection Plan as a procedural upgrade to reflect current decommissioning methodology acceptable to the NRC staf A TSCR is needed to release the outbuildings from the facility i surveillance requirements. The licensee plans to make the decontaminated outbuildings available for an NRC inspection at the completion of decontamination activities (projected Fall 1987).

The inspector had no additional comments on these matter .0 Exit Meeting

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l An exit meeting was held on July 23, 1987, with the licensee and NRC personnel denoted in Section 1.0 in attendance. At that time, the scope,

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content, and findings of the inspection were summarized.

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