IR 05000237/1999015
| ML17191B433 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/01/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17191B432 | List: |
| References | |
| 50-237-99-15, 50-249-99-15, NUDOCS 9909080173 | |
| Download: ML17191B433 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION Docket Nos:
License Nos:
Report Nos:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved b~:
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9909080173 990901 PDR ADOCK 05000237 G
PDR REGION Ill 50-237; 50-249 DPR-19; DPR-25 50-237 /99015(DRS); 50-249/99015(DRS)
Commonwealth Edison Company (ComEd)
. Dresden Nuclear Generating Station, Units 2 and 3 6500 N. Dresden Road Morris, IL 60540*
August 9-13, 1999 W. Slawinski, Senior Radiation Specialist A. Kock, Radiation Specialist
Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
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EXECUTIVE SUMMARY Dresden Nuclear Generating Station, Units 2 and 3 NRC Inspection Reports 50-237/99015(DRS); 50-249/99015(DRS)
This routine, announced inspection assessed the effectiveness of the licensee's programs for the management of solid radioactive waste (radwaste) and for the transportation of radioactive material and radwaste. Specifically, the inspectors evaluated the implementation of the licensee's process control program (PCP) for processing waste streams into forms acceptable for land disposal and reviewed waste characterization methods, waste shipment manifesting, package preparation, and the training of staff involved in shipment activities. The inspectors also reviewed the station's audit program and assessment activities relative to waste processing and transportation, a November 1998 incident involving leakage of the liquid radwaste discharge line and the status of facilities and equipment associated with the radwaste program. Within these areas, the following conclusions were made:
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Plant Support
Experienced vendor staff and adequate licensee oversight of processing activities ensured effective implementation of the radwaste management program. Waste streams were processed onsite in accordance with vendor and licensee PCPs and *
station approved procedures, and dewatered waste streams were sampled and independently verified by station staff to ensure regulatory limits for free standing liquid were met. Plans to reduce the generation of dry active waste were developed and reduction strategies were implemented to address licensee identified deficiencies (Section R1.1 ).
The licensee's program for the classification of radwaste shipments was technically sound, effectively implemented by staff well-versed in its application and included a *
comprehensive program for scaling factor derivation, trending and analyses (Section.R1.2)..._..
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The radioactive material and radwaste packaging and transportation program *was
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effectively implemented. Shipments were appropriately classified and controlled, vehicle and package surveys were performed competently, and shipment manifests were completed in accordance with requirements (Section.. R1.3).
- A deficiency was identified with the method used by the radiation protection staff to ensure a package's contents were properly cribbed to prevent shifting during transit and discrepancies with worksheets and checklists in the shipment procedure were noted, both of which the licensee planned to address (Section R1.3).
- A November 1998 radwaste river discharge line and discharge valve flange leak was repaired, a decommissioning file was established as required by 10:CFR 50.75(g), and a radiological assessment supported the licensee's decision to postpone area remediation pending site decommissioning (Section R1.4).
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Material condition and housekeeping improvements in the radwaste building were noted and initiatives for additional, necessary improvements were ongoing (Section R2.1 ).
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Radioactive material inventory deficiencies were identified and several containers housing contaminated tools, equipment and radwaste stored.in,satellite radiologically restricted areas were not labeled in accordance with NRC requirements, resulting in a Severity Level IV Non-Cited Violation (Section R2.1 ).
The training provided to staff involved in packaging, preparation, and shipment of radioactive materials and radwaste satisfied Department of Transportation regulations and imparted an adequate level of knowledge to ensure effective program implementation. The licensee's training program also included non-required elements that enhanced the training program such as a qualification itinerary and a continuing education program for radiation protection technicians (Section R5.1)
While the licensee developed a Comprehensive audit program which was implemented sufficiently to assess safety significant aspects of the radioactive materials transportation and radwaste processing programs, recent limited surveillance activities reduced the value of the oversight program (Section R7.1 ).
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Report Details IV. Plant Support R1 Radlologlcal Protection and Chemistry (RP&C) Controls R1.1 Radioactive Waste (Radwaste) Management Inspection Scope (86750)
The inspectors reviewed the licensee's solid radwaste management program including the licensee's process control program (PCP), the vendor's PCP and associated vendor implementing procedures for the processing of radwaste streams, the licensee's involvement and oversight of radwaste processing activities, and the development and implementation of a station plan to reduce the volume of contaminated dry wastes (dr active wastes (DAW)) generated at the statio Observations and Findings The licensee's solid radwaste streams consisted of depleted ion exchange resins from condensate and radioactive waste processing systems, evaporator concentrates, filter media, irradiated metals, and various types of DAW. Wastes from Unit-1, which is being decommissioned, included resin, sludge and DA The licensee continued to employ experi~nced contractors to process wet solid wast~s to meet the waste. characteristic requirements* of 1 O. CFR Part.61. Higher radioactive content spent resins (displaying contact dose rates >15R/hr) were dewatered by vendor personnel onsite using station approved procedures, packaged in high integrity containers (HICs) to satisfy waste stability requirements and shipped directly to licensed burial sites: Lower radioactivity resins (<15 R/hr), evaporator concentrates, and filter hledia""were*-partially dewatered. onsite, _packag~~)i),1;:11C-! ~-"-~.~h!pped to a vendor*.
facility for thermal processing to meet the free standing liqul(f require'inenfS*'of.- ~ -~'-
. 1 O CFR Pait 61 :* These wastes were subsequently transferred by the vendor to a
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licensed burial site. Station laborers collected and packaged DAW from various areas.*
within.the plant and the waste was shipped to vendors for sorting, compaction or incineration, and disposal. Offsite contractor services were also used to decontaminate or process metals incident to free release or disposal. Station personnel indicated that vendor processing equipment was well maintained and functioned properly, ensuring that waste streams were appropriately processe The licensee maintained a PCP to establish the parameters and test criteria to ensure that radioactive waste was processed in a manner to ensure compliance with the requirements in 10 CFR Part 61 and with the low level disposal site licenses. The inspectors reviewed the vendor's and the licensee's PCP and determined that these documents provided sufficient information on the methodologies used to process each waste type generated at the station and were consistent with the requirements in 1 O CFR Part 61. The inspectors verified that the PCP was revised to address deficiencies previously identified by the NRC (Inspection Report 50-237/98020(DRS);
50-249/98020(DRS)) and that it was consistent with the Updated Final Safety Analysis Report and cu.rrentwaste processing.activities:
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Licensee personnel provided effective oversight of vendor onsite processing activitie For example, vendor processing procedures were approved through the station's onsite review process, processing activities were continually monitored by station radwaste staff, and the successful completion of certain processing steps were independently verified by radwaste personnel. The inspectors' review of the vendor's procedure for *
dewatering confirmed that it was consistent with regulatory requirements and included *
tests to ensure that specified requirements were met. Vendor personnel interviewed by the inspectors confirmed that station radwaste staff monitored processing activities and independently verified that these activities were completed safely and in accordance
. with procedure. The inspectors review of waste processing data sheets confirmed that dewatered waste streams met 10 CFR Part 61 limits for free standing liqui Additionally, the licensee's corporate health physics staff periodically audited offsite vendor facilities and a recent audit reviewed by the inspectors concluded that waste was properly tracked and controlled by the contracto The licensee recognized the need to reduce the amount of DAW generated at the station and took steps to identify and address deficiencies in this area. The licensee recently developed a DAW reduction plan, which focused efforts in problematic areas that resulted in unnecessary DAW generation at the plant and included a schedule of
. specific actions to address each noted deficiency. The inspectors' determined that the proposed actions adequately addressed those areas identified by the licensee as..
needing improvement. The plan implemented many of the 1997 Electric Power Research Institute (EPRI) recommendations for reduction of DAW generation and inc1uded steps to better control materials entering radiologically restricted areas (RRAs),
continued efforts to identify sources of excessive DAW production, and establishment of a management committee to support the DAW plan. Reasonably timely and realistic schedules were established to rectify past poor practices and early phases of the
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minimization plan were proceeding satisfactoril Conclusions Exp~ri~~~d vend~'r'staff.arid *adequate ra-dwaste'-staWoversight-of-processing activities ensured effective implementation of the radwaste man~gement program. Waste. *
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streams were processed onsite in accordance with vendor and licensee PCPs and *
station approved procedures, and dewatered waste streams were sampled arid *
independently verified by station staff to ensure regulatory limits for free standing liquid
- were satisfied. Plans to reduce DAW generation were developed and reduction strategies were initiated to address licensee identified weaknesse R1.2 Classification of Radwaste Shipments Inspection Scope (86750)
The inspectors reviewed the licensee's methods for determining the radioactivity content and classification of radwaste shipments, and evaluated waste stream sampling and analysis practices and scaling factor program implementation. Corporate and station radiation protection (RP) staff were interviewed about the classification program, sample analysis and waste stream scaling data and program implementing procedures were reviewed, and calculations were independently made to verify program implementatio * *
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Observations and Findings The licensee established a scaling factor program for the sampling of radwaste streams and for analysis of difficult to measure (DTM) radionuclides used to determine the concentration of waste shipments, consistent with industry guidanqe and th,e N~C's branch technical position on waste classification. The licensee sampled and analyzed Unit-2/3 waste streams that included resins from the spent resin storage tank, evaporator bottoms (concentrator waste) sludge, a variety of DAW, filter media, and occasionally powdered resin from the cleanup sludge tanks. Unit-1 samples included DAW and resin and sludge generated from a vendor supplied advanced liquid processing system and from radwaste storage tanks, respectively. Waste streams typically classified as class A were sampled biennially and those typically classified as class B or C such as resins from the spent resin tank were sampled annually, unless reactor coolant chemistry data indicated a potential shift iri waste classification. Unit-1 waste streams were sampled and analyzed annually, or previous samples*and scaling.
factor data were decay corrected since waste stream isotopic contents remained stable because Unit-1 had not operated and was defueled for many year Sample analyses were contracted to a vendor laboratory, and scaling factors were generated by the laboratory to correlate the concentration of DTM radionucliqes to more easily measured gamma emitters. Results were then averaged with recent historical data to establish waste stream specific scaling factors, which were used to calculate the radioactivity content ofwaste shipments pursuant to 10 CFR Part 61. Scaling factor data was entered into a database, and waste shipment classification was determined by a vendor supplied software program which related measured.package dose rates to the concentrations of gamma emitter The inspectors determined that the 1.icensee's scaling factor program and waste classification methods were ~echnically sound and included a comprehensive p~ocedu_re
- which provided guidance on waste stream 5C!mpling, scaling factor d~rivation;ca_nd *. :*.. *
- sp*e*cific~criteria~for=trending.re_a_ctq~ wa,~~J.,,9'1~.!T!JS!l)' data that GOUid *aff~ct wast~ stream. _
- . cla.~sification. Concentra~ions of technetium-99-(T c".:99r and' i0dine;129°(l*129);~fission~~-,; __ <-
pr0ducts riot normally'identified in the licensee'swaste_strearns, w~re sealed-'using.' *.
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boiling water reactor averages consiste*nt with industry practi~s. Industry *averages for *'
- Tc~99/l-129 were also used for Unit-1, which yielded conservative scaling data since*..
these water soluble isotopes would not be expected to appreciably.exist in the*residuat waste streams or otherwise be produced during decommissioning activities. Wa~te shipment tritium concentrations were calculated annually based on conservative assumptions of waste stream moisture content and measured reactor coolant system tritium results, which the inspectors determined to be appropriate. The staff also ensured that representative waste stream samples were obtained, that area smear surveys for'DAW were collected in appropriate plant locations, and that reasonable steps were taken to ensure that sample moisture. content was equivalent to the processed waste strea The inspectors selectively reviewed waste stream sampling information for 1998-and 1999 to date, independently calculated the activity content of recent waste shipments and compared them to the licensee's values, discussed waste classification activities with involved RP staff and determined that the scaling factor based waste classification program was implernent~d appropriately by knowledgeable staff. The inspectors also verified that reactor coolant chemistry data was trended in accordance with procedur_ l...
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- Conclusions The licensee's program for the classification of radwaste shipments was technically sound, effectively implemented by staff well-versed in its application and ineluded.a comprehensive program for scaling factor derivation, trending and analyses; R1.3 Shipment Preparation and Transportation Inspection Scope (86750}
The inspectors reviewed the radioactive material and radwaste packaging and transportation program for compliance with NRC, Department of Transportation (DOT),
and waste burial site license requirements. This review included interviews with RP staff involved in the transportation program, observation of shipment preparation activities, and inspection of records of past shipments and applicable procedure Observations and Findings Designated shipment qualified personnel provided continual oversight of the radioactive material and radwaste transportation program and ensured by direct involvement that.
packages were properly prepared, that waste destined for burial site disposal was correctly characterized, and that all applicable NRC and DOT requirements were: met
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before a shipment was certified and.its release was a~thorized from the site.'
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In most instances, the licensee used a vendor software program to.compute the activity of each package offered for transport based on dose-to-curie calculations.- In. *.. *
completing this calculation, the software accounted for the isotopic abunc:tari_ces in each waste stream and decay corrected ea.ch shipment as applicable: The inspector * independently verified that the software's activity calculations were accurate for several
~dioactive material and radwaste shipments made during 1998 and 1999 through _the
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date=of ttlErinspection~~ *A1so;-*the~licensee:s;corpor:ate_11_e~J!t1 p_hysi~. ~~~ff periodically verified the software calculations and last confirmed the accuracy on lie conf putatidr:is 'iri..
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- The inspectors reviewed Procedure DRP 5600-07; "Shipment of Radioactive Materials,".
and other procedures governing the implementation* of the transportation program and.
determined that they were consistent with the station's praetices and with DOT and NRC regulations. The inspectors also found that procedures were generally*thorough, in that they provided sufficient guidance to ensure that requirements were met. However, the licensee planned to correct inspector identified errors in the worksheets used to prepare shipments of surface contaminated objects (SCOs) and to expand procedure checklists to more fully coincide with DOT requirements. The inspectors confirmed that errors in some numerical values listed on the SCO worksheets did not affect shipment
complianc The inspectors observed the loading and preparations for two outgoing radioactive material shipments that were made during the inspection. The inspectors verified that the packages were properly marked, labeled and blocked and braced.to.satisfy DOT requirements, and that the vehicle was placarded and the driver was provided appropriate written instructions for exclus.ive use shipments. In addition, the inspectors determined that a radiation protection technician (RPT) completed comprehensive *
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radiation surveys to support shipment preparation and was knowledgeable of radiological survey requirements and associated DOT criteria. The inspectors noted, however, that shipment qualified staff only visually checked the cribbing of contaminated scaffolding and other equipment contained in two "seavans" (large packages) that were loaded weeks earlier by station laborers, a practice that RP management acknowledged should be supplemented by physical check The station made over 250 radioactive material and approximately 75 radwaste shipments during the 15 month period preceding the inspection, including several made'
directly to a low level waste burial site after onsite processing. Most radwaste shipments made during this period were sent to waste processors prior to ultimate disposition by the vendor. The inspectors verified that six selected radioactive material/radwaste shipments made since June 1998 were correctly Glassified according to 10 CFR Part 61 and DOT regulations, that scaling factors were properly applied, that package labeling and marking was satisfactory, and that results of package and transport vehicle surveys satisfied DOT requirements. The inspectors also verified that shipment manifests were completed consistent with the regulations, included proper :.
emergency response information, and that radwaste shipments were tracked as required by*10 CFR Part 2 Conclusions
. The radioactive material and radwaste packaging and transportation program was.
effectively implemented. Shipments were appropriately classified and controlled,. vehicle and package surveys were performed competently, and shipme11t manifests were
. completed in.accordance with requirements.. However, a'de(iciencywas identified with the method used by licensee staff to ensure.a package's ~ntents*were properly cribbed.'..
to prewent shifting during transit and discrepancies with shipment pro~dure wo~sheets..
and checklists were noted, both which the licensee planned to addres * *
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- The inspectors reviewed the circumstances and the licensee's actions associated withj1 leak in the radwaste river discharge line an_d isolation valve.. Licensee.RP staff we~e:.
interviewed, problem identification forms arid associated documentation were reviewed and photographs of the affected areas were viewe *
Observations and Findings l
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During work on the radwaste river discharge canal isolation valve in November 1998, the licensee identified that leakage from the valve flange contaminated the soil in the immediate vicinity of the valve. The flange leak was repaired and soil samples showed the presence of cobalt-60, cesium-137 and manganese-54 at.concentrations slightly above the lower limits of detection for environmentatsamples. Subsequently, leakage was identified in the radwaste discharge line just upstream of the isolation valve where the line emerged from the ground. The soil in the vicinity of the discharge line was excavated, the line leak repaired and additional soil characterization samples showed concentrations of radionuclides similar to those collected near the flange leak.,
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- Licensee assessments showed that the contaminated soil did not create an external radiation dose hazard or otherwise pose a radiological hazard to the environment since
. releases made from plant operations to the radwaste discharge line were controlled and evaluated for compliancewith public dose limits. According to the license~. the discharge line had been replaced several years ago because of previous line leaks, which had also deposited small quantities of radioactive material in the soil. Since the contaminated soil was located within the owner controlled area and in a posted radiologically restricted region of the site, the licensee decided to leave the soil in place and a decommissioning file was established pursuant. to the requirements of 10 CFR 50. 75(g). The inspectors evaluated the licensee's response to the problem and concluded that the licensee's actions were adequate and that the licensee's documentation satisfied regulatory requirement Conclusions A November 1998 radwaste river discharge line and discharge valve flange leak was repaired, a decommissioning file was established as required by 10 CFR 50.75(g), ar:i a radiological assessment supported the licensee's decision to postpone area remediation pending site decommissionin R2 Status of RP&C Facllltles and Equipmen R Walkdowns of Radwaste Facilities and Satellite Storage Areas Inspection Scope (86750) An inspector conducted walkdowns of the Unit-2/3 radwaste building,.the Unit.:.1
. radwaste yard and satellite RRAs where radioactive matenal and *radwaste was stored, and evaluated material eondition, housekeeping and radiologicalposting and contro_ls;.
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The i~sp~ctor ve:rified that high and-locked high radiation areas were control!ed in*. *. _.
accordance with regulatory requirements and that areas were posfe~ consistent with-.*
1 O CFR Part 20. The inspector noted that material condition in 'th~ radwaste building
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was a~equate and had improved since previously reported.(lnspection.Report, 50-237/98025 (DRS); 50-249/98025(DRS)). In particular, the licensee recently completed a floor drain hydrolazing project in the Max Recycle Area of the Radwaste Building, repaired several piping and valve leaks and reduced the backlog of DAW.in the radwaste building storage bays. While some improvements in radwaste building housekeeping were also noted, the licensee recognized that additional improvement *
was necessary to achieve the higher standards maintained in other areas of the plan To ensure continued and sustained improvement in the radwaste building, the licensee assigned one of its radwaste specialists responsibility for the area. The individual *
tracked work request completion status and provided weekly progress reports to station *
management. However, the licensee postponed completion of the Unit-2/3 main concentrator waste tank vault cleanup, a project initiated in March 1998, while problems with robotic equipment used for the cleanup were resolved arid a planned October 1999 refueling outage was completed. The licensee acknowledged that the projects postponement would impact completipn of radwaste building housekeeping initiative.*
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- Inspector walkdowns of satellite RRAs revealed problems with the labeling of several containers housing radioactive material and radwaste, and with the inventory of the materials stored in these areas. Specifically, several seavan containers located in the Unit-1 radwaste.yard and housing a variety of tools and equipment contaminated with small but unknown quantities of radioactive material were not labeled to indicate _that the containers stored radioactive material. Similarly, approximately ten QB-25" boxes stored in an outdoor area adjacent to the Interim Radwaste Storage Facility and housing *
contaminated soil and equipment were either not labeled to indicate the presence of radioactive material, or existing labeling was weathered and worn and label information was not legible. In addition, the specific radioactive content of the containers was unknown because inventories were not completed. Therefore, the labeling exemptions of 10 CFR 20.1905 did not apply even though radiation work permits controlled entry into these area CFR 20.1904 requires that each container of licensed material bear a durable, clearly visible label bearing the radiation symbol and the words ucaution, Radioactive Material" or uDanger, Radioactive Material." The label must also-provide sufficient radiological information to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions necessary to avoid or minimize exposure The failure to clearly label the B-25 boxes and the seavan containers are examples of a violation of 10 CFR 20.1904~ This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy (50-237199015-01 (DRS); 50-249/99015-01 (DRS)).
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After the labeling problem was brought to the licensee's attention, the containers identified by the inspector were labeled and the licensee walked down other satellite RRAs to ensure that no other unlabeled containers existed. Problem Identification Form (PIF) # 99-321 was generated and the violation was entered into the licensee's corrective action program. The licensee recognized the need for a radioactive material * *
inventory system and a corporate procedure was drafted to address that deficiency..
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Conclusions Material condition and housekeeping improvements-.in the radwaste building were noted and initiatives for additional, necessary improvements were ongoing. Radioactive *
material inventory deficiencies were identified and several containers housing contaminated tools, equipment and radwaste maintained in satellite RRAs were not labeled in accordance with NRC requirements, resulting in a Severity Level IV Non-Cited Violatio R5 Staff Training and Qualifications In RP&C R Training of Staff Involved in the Transportation of Radioactive Material and Radwaste Inspection Scope (86750)
The inspectors reviewed the training provided to station staff involved in radioactive material transportation activities (Le., hazardous material (hazmat) employees). The inspectors discussed the training program with* station staff; reviewed training_
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certificates, test results, and lessons plans; and evaluated qualification criteria for RP and chemistry staff involved in radioactive material transpor Observations and Findings The licensee identified individuals who were responsible*for*ensuring that radwaste and radioactive materials were properly packaged and prepared for transport and designated several ushipping qualified personnel" who were approved to sign radioactive materials shipping papers and authorize the release of shipments. These individuals
- verified that packages were properly marked and labeled, that waste destined for burial site disposal was properly characterized, and that all NRC and Department of Transportation requirements were met before certifying the shipment and authorizing its release. In addition, several shipping uinspectors" were assigned to provide oversight of packaging and surveys during shipment activities, RPTs were assigned radiation survey responsibility, and station laborers were responsible for loading and unloading packages containing radioactive materia The inspectors reviewed the training lesson plans, training certificates, and test results
. for selected* individuals involved in the shipping and receipt of radioactive material packages. The inspectors' review determined that the course material provided to these hazmat employees satisfied 49 CFR 172.704.requirements, that the information provided was accurate, that recurrent training was provided at the required interval.* and that appropriate personnel completed hazmat training. The licensee tested the workers on the information provided, as required, and maintained documentation to demonstrate*
that workers successfully completed the courses. Interviews of shipping qualified personnel revealed that they were very knowledgeable of pertinent transportation requirement *
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Although not a regulatory requirement, the station also developed on-the-job
.. gl!~l!fication programs for RPTs.and shipping inspectors involved.in*radioactive material shipping-~activities~ "The inspectors*reviewed,th~s.e.. Ql!ajlfJcation criteria arid noted'that they included ele.m~~ts that would effectively assess workeFknoWledge* and covered, :.*..
pertinent transportation requirements and industry events. The Rf>T quaJification criteria*
also included annual performance based continuing education which required that the --*
technicians properly respond to hypothetical shipping scenarios. * *
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The training provided to staff involved in packaging, preparation, and shipment of radioactive materials and radwaste satisfied DOT regulations and imparted an adequate level of knowledge to ensure effective program implementation. The licensee's training program also included non-required elements that enhanced the training program such as a qualification itinerary and a continuing education program for RPT. -- *...
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R7 Quality Assurance In RP&C Activities R Audits and Assessments of Radwaste Processing and Transportation Inspection Scope (86750)
The inspectors reviewed the quality assurance (QA) program to assess *the station's ability to identify and correct problems reiated to radwaste processing and transportation of radioactive materials. Specifically, the inspectors interviewed nuclear oversight department (NOD) and RP personnel and reviewed NOD field observations completed between July 1998 and August 199 Observations and Findings The inspectors determined that the NOD audit program was generally comprehensive *
and included aspects essential for effective problem identification and resolution. For example, the station's master audit plan (MAP) was developed based on Institute for *
Nuclear Power guidelines and included areas for inspection that were similar to those included in NRC inspection procedures. To ensure the proper level of oversight, the plan permitted adjustment of audit frequency and scope based qn previous finding Lead auditors developed specific issues to be addressed and guidance on inspection techniques to ensure that each area was sufficiently evaluated. In. addition, the station had recently implemented a continuing assessment program which was expected to.
permit more thorough assessments, in that the revised plan permitted longer review *
times and provided more structured guidance regarding areas to be reviewed. Timely resolution of audit findings was accomplished th.rough a NOD database tre1cking system and the plant's corrective action system. An appropriate level of independence among * *
audit team members was accomplished by including individuals from other station The insp~ctors..reviewed the NOD staffs implementation of.the radwaste proC;essing *and transportatlon"atiait* prdgra*m*:- Audits* oMhe,radwaste,a.nd. transpq~t~c;m et<?.Q!!!TI~~~~re conducted biennially as requi~ed by the station's QA program and MAP and problems.-_*-*
identified were addressed in a timefy manner;:as documented'in'-lrisp~ction: __ : * __ *. - ' *.
Report 50-237/98020(DRS); 50-249/98020(DRS). In accordance with station
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procedure, the NOD supplemented ttif;! formal assessments with field observations,.** *
which were performed at the discretion of the oversight group.. Although these audit activities ensured that safety significant-issues were addressed, there were minimal surveillance activities related to implementation of the waste processing or radioactive material shipment programs since the last formal audit. Specifically, although field
- observations focused on radiological work practices during radwaste operations, there were no field observations or other NOD assessments of vendor processing activities or shipment activities since at least July 1998. During this thirteen month period, numerous opportunities existed to conduct performance based reviews of these activities, in that approximately 300 shipments were made and several waste streams were processed onsite. Other than an informal self-assessment completed on August 4-6, 1999, the RP staff also did not recently evaluate implementation of these program areas. In addition, according to NOD staff,* review of the station's waste classification methods and scaling factor program were not routinely included in their field observations or audits, in part, because station staff lacked expertise in this are *while the licensee's *recent performance in the areas of radwaste processing and transportation has been good, the licensee acknowledged that increased oversight in
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- these program areas would permit proactive identification of potential problems and add value to the progra Conclusions
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While the licensee developed a comprehensive audit program which was implemented sufficiently to assess safety significant aspects of the radioactive materials transportation and radwaste processing programs; recent limited surveillance activities reduced the value of the oversight progra V. Management Meetings XI Exit Meeting Summary The inspectors presented the inspection results to Mr, Heffley and other licensee management and staff at the conclusion of the inspection on August 13, 1999. The licensee acknowledged the inspection findings and identified no proprietary informatio.. ~'
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PARTIAL LIST OF PERSONS CONTACTED J. Almon, Training Manager D. Ambler, Regulatory Assurance Manager S. Bell, Shipment Health Physicist (Corporate)
D. Doggett, Radiation Protection Field Operations Supervisor R. Fisher, Operations Manager T. Fisk, Chemistry Supervisor M. Gagnon, Shipment Health Physicist D. Haney, Chemistry Radwaste Specialist M. Heffley, Site Vice President R. Kelly, Regulatory Assurance, NRC Coordinator C. Kolotka, Chemistry Radwaste Specialist W. Lipscomb, Executive Assistant J. Moser, Radiation Protection Manager L. Oshier, Radiation Protection Technical Support Supervisor M. Pacilio, Work Control Manager M. Pavey, Nuclear Oversight Assessor B. Stoffels, Maintenance Manager J. Stone, Nuclear Oversight Manager D. Villicana, Radiation Protection Training Administrator INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive Materials
Opened 50-237/99015-01 50-249/99015-0 Closed
~ 50-237/99015-01 50-249/99015-01 Discussed None iTEMS--OPENED, ClOSED,-AND DISC.USSED
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NCV Failure to label containers housing radioactive materials and- '.
stored in satellite radiologically protected areas.*
NCV Failure to label containers housing radioactive materials and stored in satellite radiologically protected area. ~-
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CFR DAW DOT DTM EPRI Hazmat HIC LSA MAP NOD PCP PIF QA Radwaste RP RP&C RRA RPT *
LIST OF ACRONYMS USED Code of Federal Regulations Dry Active Waste Department of Transportation Difficult to Measure Electric Power Research Institute Hazardous Material High Integrity Container Low Specific Activity Master Audit Plan Nuclear Oversight Department Process Control Program Problem Identification Form Quality Assurance '
Radioactive Waste Radiation Protection Radiological Protection and Chemistry Radiologically Restricted Area Radiation Protection Technician
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PARTIAL LIST OF DOCUMENTS REVIEWED Station Procedures DRP 5600-07, -(Rev 02), Shipment of Radioactive Material DRP 5600-03, (Rev 01 ), Classification of Radioactive Waste DRP 5610-06, (Rev 06), Surveying Radioactive Material Shipments DRP 5600-13, (Rev 02), 10 CFR 61 Waste Stream Sampling and Analysis OAP 07-02, (Rev 4), Dresden.Nuclear Power Station Process Control Program OAP 09-05, (Rev 07), Review and Approval of Non-Station Work Group Procedures N0-31, (Rev 1 ), Field Observation Program N0-38, (Rev t), Master Audit Plan Other Documents *
10 CFR 50. 75 (g) file #99-003, Radwaste Line Discharge Valve Leak ~~a. *
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Shipment Manifests and Associated documentation for:
- Shipment# 99-136, August 11, 1999, (Unit2/3DAW)
Shipment# 99-127; June 30, 1999, (Ui1it1 DAW)
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Ship~ent#*1198-8742, November 19, 1998,* (Unit 2/3 Dewatered Spent Resin) : *
Shipment# 99-122, June 28, 1999, (Unit 2/3 Concentrator Waste)
Shipment # 99-9132, May 21,, 1999, (Unit 2/3 Irradiated Hardware)
--Shipment~#.98-0233, November..20, J 998,_(Uoil V.3 DAW)
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Dewatering Procedure for CNS 14-215 or Smaller Liners. *
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Chern-Nuclear Systems, Inc. Document DM-OP-022,.(Rev.05), Process Control Program for CNSI Liquid Waste Processing System *
Dresden Updated Final Safety Analysis Report, (Rev 3), Chapter 11.4, Solid Waste
- Management Syste Lesson Plan, Level II Radioactive Materials Shipping Training, (Rev 3).
Lesson Plan, Radioactive Materials Shipping, (Rev 14).
Lesson Plan, Radioactive Materials Shipping Initial training, (Rev 3).
Package Vehicle Inspector On-the-Job training Manual, (Rev 0).
Qualification.Checklist 12T0604,." Inspect, Prepare, Control, and Su..Vey Radioactive Shipments", (Rev 1 ).
Qualification Checklist 12T0605, "Perform Surveys of Radioactive Materials Received", (Rev 3).
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