IR 05000285/1994013
| ML20029D499 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/01/1994 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20029D498 | List: |
| References | |
| 50-285-94-13, NUDOCS 9405060034 | |
| Download: ML20029D499 (12) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-285/94-13 Operating License: DPR-40 License 9:
Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 Facility Name:
Fort Calhoun Station Inspection At:
Blair, Nebraska Inspection Conducted: April 18-22, 1994 Inspectors:
J. B. Nicholas, Ph.D., Senior Radiation Specialist Facilities Inspection Programs Branch W. L. Holley, Senior Radiation Specialist Facilities Inspection Programs Branch n
Approved:
/~f BTaine(Murray, Chief, Facilities Inspection Date
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Programs Branch Inspection Summarv Areas Inspected: Routine, announced inspection of the solid radioactive waste management and transportation programs.
Results:
Organizational structure and staffing of the radiation protection
department and radioactive waste operations group met Technical Specification requirements (Section 1.1).
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The radioactive waste operations group had experienced a low turnover of
personnel, and the personnel changes had no negative effect on the performance of the solid radioactive waste management and transportation programs (Section 1.1).
Good radiation protection department and radioactive waste operations
group management controls were being implemented (Section 1.1).
9405060034 940504 PDR ADOCK 05000285 G
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2-A good training program for the radioactive waste operations group
personnel was being implemented (Section 2.1).
The radioactive waste operations group was fully staffed with qualified
and experienced personnel to perform solid radioactive waste processing and transportation activities (Section'2.1).
Good quality assurance audits and surveillances.of the solid radioactive
waste management and transportation programs were performed by qualified auditors and provided good program evaluation and management oversight (Section'3.1).
Audits of the contractors used.to perform solid radioactive waste.
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processing and volume reduction and. laboratory analyses were performed '
(Section 3.1).
Good procedures that addressed the processing, packaging,. handling,
l classification and characterization, and transporting-of radioactive waste and materials were maintained (Section 4.1).
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A. good radioactive waste minimization program ~was being implemented
(Section 4.1).
A good solid radioactive waste' management program was'being implemented
(Section 4.2).
Solid radioactive waste was analyzed for the determination of
radionuclide concentrations and scaling factors (Section 4.3).
l Interim storage for radioactive waste was provided in the radwaste
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building (Section 4.4).
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l The quality assurance program for radioactive material packages was NRC
approved (Section 5.1).
Good implementing procedures that addressed selection of packages, j
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preparation of packages for. shipment, and delivery of the completed packages to the carrier were maintained (Section 5.1).
The solid radioactive. waste. transportation program was being implemented
in accordance with regulatory. requirements (Section. 5.1).
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. Personnel responsible for the shipment and transportation of radioactive
waste and/or materials were knowledgeable of the regulatory requirements and the burial site license conditions (Section 5.1).
Radioactive Effluent Release Reports were submitted in a timely manner, l
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and the reports contained all the required information presented in the-recommended format (Section 6.1).
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-3-Attachment:
Attachment - Persons Contacted and Exit Meeting l
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DETAILS p
1 ORGANIZATION AND MANAGEMENT CONTROLS (86750)
The inspectors reviewed'the organization and staffing of the radiation protection department to determine agreement with commitments in Chapter 12 of the Updated Safety Analysis Report'and' compliance with the requirements in Technical Specification 5.2.
1.1 Discussion The inspectors rev.iewed the organizational structure of the radiation protection department and specifically the radioactive waste operations group which was' responsible for the management and implementation of the solid radioactive waste management and transportation programs. The inspectors reviewed the organizational and staffing changes 'in the radioactive waste operations group since the previous NRC inspection of this area..The changes included the replacement of the radioactive waste operations. supervisor and the radioactive waste operations coordinator.
The number.of health physics
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technicians assigned to the radioactive waste operations group was reduced from five to'three technicians. The personnel changes during the past 2 years had no negative effect on the performance of the solid radioactive waste-management and transportation programs.
The organizational structure and.
staffing of the radiation protection department-was as defined in the Updated Safety Analysis Report and Technical Specifications. -Radiation protection departmental administrative procedures were reviewed for the assignment of responsibilities for the management and implementation of the solid radioactive waste management and transportation programs. The inspectors determined that the duties and responsibilities specified in the station-
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procedures were being implemented, and that the solid radioactive waste management activities'were well managed.
The radioactive waste operations group, which included a supervisor, a coordinator, and three health physics technicians, was fully staffed. Radioactive waste operations group personnel were trained and qualified and were responsible for performing the required solid radioactive waste management and transportation of radioactive materials activities in accordance with the Offsite Dose Calculation Manual, Process Control Program, and NRC and Department of Transportation requirements.
The inspectors interviewed several of. the radioactive _ waste operations group personnel and determined that they were familiar with the requirements of-the solid radioactive waste management and transportation programs and maintained a high level of performance.
1.2 Conclusions-The organizational structure and staffing of the radiation protection department met the commitments in the Updated Safety Analysis Report and the requirements in the Technical Specifications. During the past 2 years, the radioactive waste operations group had experienced a low turnover of personnel.
The personnel changes had no negative effect on the performance of the solid radioactive waste management and transportation programs.
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4-5-protection department and radioactive waste operations group management coc+rols were being implemented in accordance with station procedures.
2 TRAINING AND QUALIFICATIONS (86750)
The inspectors reviewed the training and qualification programs for the radioactive waste operations group personnel responsible for implementing the i
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solid radioactive waste management and transportation programs to determine agreement with commitments in Chapter 12 of the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 5.3 and 5.4.
2.1 Discussion The inspectors discussed the radioactive waste operations group training and
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qualification program with the chemical and radiation protection training supervisor. The inspectors reviewed lesson plans, selected performance evaluation checklists, and vendor course materials for the 5-day course on radioactive waste packaging and shipping which was presented biennially to train and requalify the radioactive waste operations group personnel.
The inspectors also reviewed selected completed performance evaluation checklists and training records for all radioactive waste operations group personnel.
Based on the review, it was determined that the training and training materials were of good quality and that the radioactive waste operations coordinator and the health physics technicians currently responsible for the processing and transportation of solid radioactive materials had completed the required training to perform their assigned duties.
The licensee had implemented a biennial frequency for radioactive waste packaging and transportation regulatory requirement. training. The inspectors determined that the radioactive waste operations group personnel had completed the regulatory requirement training within the past 2 years and were knowledgeable of the applicable NRC, Department of Transportation, and burial site license reouirements.
It was noted that the radioactive waste operations supervisor had only been in that position for one year and had not completed all of the station's training department training which was equivalent to the other personnel in the radioactive waste operations group.
However, it was verified that he had attended an off-site vendor course which provided training on the requirements for transportation and packaging of radioactive materials.
2.2 Conclusions A good training program for the radioactive waste operations group personnel was being implemented.
The radioactive waste operations group was fully staffed with qualified and experienced personnel to perform solid radioactive waste processing and transportation activities.
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3 QUALITY ASSURANCE PROGRAM (86750)
The inspectors reviewed the quality assurance audit and surveillance programs regarding the solid radioactive waste management and transportation programs to determine agreement with the commitments in Chapter 11 of the Updated Safety Analysis Report and compliance with the requirements in Technical Specification 5.5.2..
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-6-3.1 Discussion The inspectors reviewed the quality assurance 1991-1994 audit schedule issutd March 29, 1994.
This schedule reflected a biennial audit schedule for'the solid radioactive waste management control and transportation programs (Process Control Program).
The audit schedule indicated that the Process Control Program audit was to be performed in the last half of the odd numbered years. The audit. schedule was in compliance with the Technical Specification audit frequency requirement.
The inspectors reviewed the quality assurance audit plan and the qualifications of the quality assurance auditors who performed the audit of the Process Control Program.
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The inspectors reviewed the 1991' and 1993 reports of the quality assurance audits of the " Process Control Program" (63B), which were conducted during the time periods November 4-14, 1991, and August 9-23, 1993, for scope, thoroughness of program evaluation, and timely followup of identified
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deficiencies.
The audits were performed by teams of qualified personnel, who were knowledgeable in solid radioactive waste management and transportation-programs. The audits were conducted in accordance with quality assurance procedures and schedules.
The audit teams evaluated the implementation of the solid radioactive waste management and transportation programs. As a result of the 1991 audit, four Corrective Action Reports were issued. Three of the four Corrective Action Reports identified deficiencies of procedural noncompliance and the fourth identified the failure to utilize an Institute Nuclear Power Operations Guideline. The inspectors reviewed the corrective actions taken to resolve the audit deficiencies and verified that the audit deficiencies were closed promptly. The 1993 audit indicated effective radioactive waste management and transportation programs were being implemented, and no Corrective Action Reports were issued. The 1991 and 1993 audits of the Process Control Program were comprehensive and of good quality
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and satisfactory to evaluate the licensee's performance in. implementing the solid radioactive waste management and transportation programs. They were conducted in agreement with Updated Safety Analysis Report commitments and met Technical Specification requirements.
The inspectors reviewed 9 quality assurance surveillances of the solid radioactive waste management and transportation programs activities. The inspectors determined that the quality assurance surveillances of the solid radioactive waste management and transportation programs were comprehensive and conducted at a sufficient frequency to evaluate the licensee's compliance with Technical Specification and Process Control Program requirements. Two deficiencies were identified while performing the quality assurance surveillances. Corrective Action Reports were issued to document the identified deficiencies.
The inspectors reviewed the corrective actions taken to resolve the identified deficiencies and verified that the deficiencies were closed promptly.
The quality assurance surveillances were of good quality and
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satisfactory to evaluate the licensee's performance and provide periodic management oversight.
The licensee used a contractor to provide various cadwaste services such as incineration, compaction, wet waste processing, solidification, and shipment of solid radioactive waste for burial after processing and volume reduction.
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-7-The licensee used a contractor laboratory to perform radiochemical analyses of the station's various liquid and solid radioactive waste as required in 10 CFR Part 61 to classify and characterize the solid radioactive waste prior to disposal. The licensee had performed audits of the solid radioactive waste processor and the contractor laboratory.
3.2 C_oncl u sion s Good quality assurance audits and surveillances of the solid radioactive waste management and transportation programs were performed by qualified auditors.
The audits and surveillances were comprehensive and provided good program evaluation and management oversight. Audits of the contractors used to perform solid radioactive waste processing and volume reduction and laboratory analyses were performed.
4 SOLID RADI0 ACTIVE WASTE MANAGEMENT (86750)
The inspectors reviewed the solid radioactive waste manageinant and transportation programs to determine whether these programs met applicable regulatory requirements.
4.1 Changes to the Program The inspectors reviewed changes since the last inspection of this area that were made in the facilities, equipment, program, and procedures that affected the performance of the solid radioactive waste management program.
The licensee had made several changes to the radioactive waste operations
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procedures and associated data forms used by the radioactive waste operations group in processing, packaging, handling, and transporting radioactive waste and materials and the Process Control Program since the previous NRC l
inspection of this area. The inspector reviewed selected revised procedures
and noted that they provided detailed specific instructions for performing individual job task requirements. The procedures were easy to follow and were i
specifically directed toward compliance of regulatory requirements.
The licensee had established and implemented a good radioactive waste minimization
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program.
I 4.2 Solid Radioactive Waste Management The inspectors reviewed the solid radioactive waste management program to determine agreement with commitments in Chapter 11 of the Updated Safety i
Analysis Report and compliance with the requirements of-the Process Control Program.
The licensee disposed of radioactive spent resin by transferring and dewatering the spent resin in high integrity containers and shipping the high integrity containers off site to a licensed radioactive waste burial site.
Extensive use of procedure checklists was noted.
Quality control inspectors were present during the shipments of the high integrity containers and
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i i-8-conducted their own independent inspections of the shipments and shipping documentation.
The inspectors noted that the shipments were prepared,
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inspected, and documented by radioactive waste operations group personnel and
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quality control inspectors in accordance with regulatory requirements. The licensee disposed of dry active waste by placing it in sea-land containers and shipping it off site to a contractor who segregated and processed it for solume reduction prior to shipment for burial.
The inspectors reviewed selected radioactive waste shipping manifest forms and shipping papers that accompanied each shipment of radioactive waste. The completed shipping manifests and documentation reviewed complied with the requirements of 10 CFR 20.2006.
4.3 Radioactive Waste Classification. Waste Characterization, and Shipping Reauirements The inspectors reviewed the licensee's program for the control, classification, characterization, and shipment of solid low-level radioactive waste and disposal site license conditions to determine compliance with the requirements of 10 CFR 20.2006, 61.55, and 61.56, and the recommendations of NRC Branch Technical Position, Revision 1, " Papers on Low-level Radioactive Waste Classification and Waste Form."
The inspectors determined that the licensee had sent annual samples of dry active waste to a contract laboratory during 1991, 1992, and 1993 and samples of solid radioactive waste from individual batch shipments for special analyses to determine radionuclide concentrations and scaling factors for those radionuclides which the licensee was not capable of directly measuring.
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The inspectors reviewed the licensee's analytical records for selected waste samples of solid radioactive waste and scaling factor information generated for characterizing the solid radioactive waste prior to shipment to meet 10 CFR Part 61 requirements.
4.4 Interim Storage of Solid Radioactive Waste As part of the 1icensee's long range radioactive waste management plan, the licensee was keeping abreast of the radioactive waste burial site development in their compact and had provided for interim storage of their radioactive waste on site for a minimum of 5 years if the current burial site was closed to them in July 1994 and the compact burial site in Nebraska was not ready to receive radioactive waste.
The inspector inspected the licensee's radioactive waste. interim storage area inside the radwaste building and noted that it was secured, posted properly, and provided ample interim storage space for more than the amount of radioactive waste that would be generated by the station in 5 years.
4.5 Conclusions Good procedures that addressed processing, packaging, handling, classification and characterization, and transporting of radioactive waste and materials were
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maintained.
The licensee was implementing a good radioactive waste minimization program. A good solid radioactive waste management program was
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being implemented.
The licensee had analyzed solid radioactive waste for the determination of radionuclide concentrations and scaling factors. The licensee provided for interim storage of their radioactive waste inside the radwaste building, j
5 TRANSPORTATION OF RADI0 ACTIVE MATERIALS (86750)
The inspectors reviewed the transportation program for shipment of radioactive materials and solid radioactive waste to determine compliance with the requirements in 10 CFR Parts 20, 61, and 71; and 49 CFR Parts 172-189.
5.1 Discussion 5.1.1 Quality Assurance Program The inspectors verified that the licensee had received NRC Form 311, " Quality Assurance Program Approval," which documented NRC approval that the licensee's submitted quality assurance program complied with 10 CFR Part 71, Subpart H, for the transportation of radioactive materials.
The approval expires July 31, 1994.
5.1.2 Procurement and Selection of Packages The inspectors reviewed the licensee's procurement of Department of Transportation and NRC certified containers.
The licensee used strong-tight containers for the shipment of low specific activity dry radioactive waste and laundry. Of the 217 shipments made in 1991, 1992, and 1993, 13 shipments were for burial of Type A dewatered resins or spent filter cartridges shipped in high integrity containers placed inside certified shipping casks for shipment to the burial sites and 157 shipments were for burial of Type B dry compressible waste or contaminated equipment shipped for burial by exclusive use vehicles.
The remaining radioactive materials shipments were of laundry, radioactive sources, chemistry samples for analyses, and dry active waste or radioactive materials that were being shipped to a contractor for processing and volumr reduction.
The licensee maintained current documentation on the manufacturer's design testing, maintenance, and NRC Certificates of Compliance for all radioactive waste certified containers and casks used by the licensee.
5.1.3 Preparation of Packages for Shipment The inspectors verified that the licensee had procedures and checklists for the preparation of radioactive waste and materials shipments. A review of the licensee's procedures and shipping records and discussion. with the radioactive waste operations group personnel indicated that the certified cask's manufacturers handling, loading, and inspecting procedures were used in preparing shipping casks for shipment. The procedures provided for visual inspection of the package prior to filling the container, instructions for closing and sealing the container, marking and labeling requirements, and determining compliance with radiation and contamination limits. The licensee routinely used a checklist to assure that procedures were followed, and that packages were prepared properly for shipment in accordance with NRC, Department of Transportation, state, and burial site requirements.
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i-10-Discussions with radioactive waste operations group personnel involved in.the.
preparation of packages of radioactive waste and materials for shipment indicated that they possessed an excellent knowledge of the licensee's procedures and NRC and Department of Transportation regulations pertaining to the preparation of packages for shipment.
The licensee maintained current transport permits for transportation of radioactive materials to or through the states of Tennessee, South Carolina, and Oregon. The licensee also maintained current copies of radioactive material. licenses for recipients of shipped radioactive waste and materials.
5.1.4 Delivery of Completed Packages to Carriers-The inspectors verified that the licensee's procedures included the required.
NRC and Department of Transportation regulations. A review of selected records and shipping papers for radioactive waste shipments indicated that the licensee had prepared appropriate manifests and shipping papers in accordance with approved procedures, and that the shipping papers included the necessary information to comply with regulatory requirements. The licensee used only exclusive use carriers for all radioactive. waste shipments and assured that the following items were in accordance with NRC and Department of Transportation regulations and station procedures:
radiation levels were within required limits, transport vehicles were placarded properly, surface contamination on packages did not exceed requirement -levels, and. blocks and/or braces were in place to prevent damage or shifting of the load during transit.
5.1.5 Records, Reports, and Notifications The inspectors reviewed selected records of several different types of waste shipments made by the licensee during 1991, 1992, and 1993. The shipments
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were adequately documented to meet NRC and Department of Transportation regulations.
The licensee maintained records of all radioactive waste and/or materials shipments as required. The records included all shipping documentation, radiation surveys, and required notification information.
5.2 Conclusions The quality assurance program for radioactive material packages was NRC approved. Good implementing procedures that addressed selection of packages, preparation of packages for shipment, and delivery of the completed packages to the carrier were maintained. The solid radioactive waste transportation program was being implemented in accordance with regulatory requirements.
Personnel responsible for the shipment and transportation of radioactive waste and/or materials were knowledgeable of the regulatory requirements and the burial site license conditions.
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6 REPORTS OF RADI0 ACTIVE EFFLUENTS AND RADI0 ACTIVE WASTE SHIPMENTS (86750).
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The inspectors reviewed reports concerning the solid radioactive waste shipments and transportation activities ~to determine compliance with the requirements of 10 CFR Part 50.36(a)(2) and Technical Specification 5.9.4.a and the Offsite Oose Calculation Manua.
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l-11-6.1 Discussion The inspectors revi.wed the Radioactive Effluent Release Reports for the time period January 1, 1991, through December 31, 1993.
These reports were written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, included the information required by the Offsite Dose Calculation Manual and provided a summary of the radioactive solid waste shipped from the station for l
processing and/or burial. The inspectors reviewed the latest changes to the Process Control Program'(Revision 2, February 1993, and Revision 3, July 1993).
Revision 2 consisted of removal of references to radioactive waste burial in the state of Washington and references that no longer applied to the station's solid radioactive waste management program.
Revision 3 consisted of incorporating appropriate 10 CFR Part 20 changes.
During the time period January 1, 1991, through December 31, 1993, the inspectors reviewed the licensee's records for shipment. of solid low-level radioactive waste, and noted that the licensee had completed 170 radioactive waste shipments by exclusive use vehicle to burial sites in South Carolina and Nevada and one waste processing site in Tennessee..The licensee had not made any shipments of spent fuel.
The inspectors reviewed the licensee's records of radioactive waste shipments for burial since 1989. The following table. summarizes the total volume and curie content of the solid low-level radioactive waste shipped for the period 1989 through 1993.
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175.32 8.76 1990
121.98 7.07 1991
37.77 19.65 1992
64.47 440.98 i
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24.28 12.68
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6.2 Conclusion Radioactive Effluent Release Reports were submitted in a timely manner, and the reports contained all the required information presented in the recommended format.
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ATTACHMENT 1 PERSONS CONTACTED 1.1 Licensee Personnel
- W. C. Jones, Senior Vice President M. P. Anderson,' Health Physics Technician
- R. L. Andrews, Division Manager, Nuclear; Services I
M. A. Breuer, Senior Health Physics Technician
- J. W. Chase, Plant Manager A. G. Christensen, Supervisor, Radiation Protection Operations
- G. M. Cook, Supervisor, Station Licensing D. W. Dale, Supervisor, Operations Quality Assurance
- J. K. Gasper, Acting Division Manager, Nuclear Operations
- W. G. Gates, Vice President
- R. G. Haug, Supervisor, Chemical and Radiation Protection Training
- T. W. Jamieson, Supervisor, Radioactive Waste Operations
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L. T. Kusek, Manager, Nuclear Safety Review
- D. L. Lovett, Supervisor, Radiation Protection J. M. Mattice, Radwaste Operations Coordinator
- E. P. Matzke, Station Licensing Engineer W. W. Orr, Manager, Quality Assurance / Quality Control T. L. Patterson, Division Manager, Nuclear Operations
- R. L. Phelps, Acting Division Manager, Plant Engineering L. D. Sills, Quality Assurance Lead Auditor
- F. K. Smith, Supervisor, Chemistry M. S. Wilwerding, Senior Health Physics Technician l
1.2 NRC Personnel
i R. V. Azua, Resident Inspector l
- R. P. Mullikin, Senior Resident Inspector in addition to the personnel listed above, the inspectors contacted other i
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personnel during the inspection.
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- Indicates those present at the exit meeting on April 22,'1994.
2 EXIT MEETING An exit meeting was conducted on April 22, 1994.
During this meeting, the inspectors reviewed the scope and findings of the inspection. The licensee did not express a position on the inspection findings documented-in this report. The licensee did not identify as proprietary any information provided i
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to, or reviewed by, the inspectors.
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