IR 05000285/1998016

Insp Rept 50-285/98-16 on 980706-10.Violations Noted.Major Areas Inpected:Solid Radwaste Mgt & Radioactive Matls Transportations,Associated Training Activities & QA Oversight

ML20236W304
Person / Time
Site:	Fort Calhoun
Issue date:	07/29/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236W292	List: IR 05000285/1998016 ML20236W289 ML20236W293
References
50-285-98-16, NUDOCS 9808050195
Download: ML20236W304 (12)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-285 License No.: DPR-40 Report No.: 50-285/98-16 Licensee: Omaha Public Power District Facility: Fort Calhoun Station Location: Fort Calhoun Station FC-2-4 Adm., P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates: July 6-10,1998 l- Inspector: Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information l

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9808050195 980729 P PDR ADOCK 05000285 G PDR ,,

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EXECUTIVE SUMMARY I

Fort Calhoun Station NRC Inspection Report 50-285/98-16 This routine, announced inspection reviewed the solid radioactive waste management and radioactive materials transportation programs. Included in the inspection were reviews of associated training activities and quality assurance oversigh Plant Sucoort l

. A violation, with four examples, of Technical Specification 5.8.1 was identified related to the solid radwaste management program because the waste stream sampling and l internal quality assurance procedure was not implemented properly (Section R1.1).

. Good performance was noted in the radioactive materials transportation progra Packaging was correctly chosen, surveyed, marked, and labeled (Section R1.2). ;

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- Documentation associated with solid radwaste management and transpt.tation activities ;

was insufficient to demonstrate the bases for some licensee decisions. Some records i were missing or incorrectly completed. Some forms were outdated (Section R3). !

. Proper training was provided to radiation workers and to specialists that were involved in the transfer, packaging, and transport of low-level radioactive waste and radioactive material (Section 5).

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. Management oversight of the solid radwaste management program and radioactive transportation activities was minimal (Section R7). l l

. An unresolved item was identified pending the licensee's attempt tu locate l documentation that authorized a change from annual audits to biennial audits of the !

radioactive materials transportation program (Section R7). ,

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-3-Reoort Details

' IV. Plant SMRRatt R1 Radiological Protection and Chemistry Controls R1.1 Implementation of the Solid Radioactive Waste Program Insoection Scoce (86750)

The inspector interviewed licensee personnel and reviewed the following:

. Regulatory references and updates

. Solid radwaste disposal totals

. Waste storage

. Waste stream sample results  !

. Work sheets for 10 CFR Part 61 waste classification l

. Waste shipment manifests Observations and Findings ]

Waste Generation According to license 9 records, the volume and activity of solid radioactive waste disposed by the licensee increased during 1995-1997. The values are listed belo Licensee personnel stated that leaking fuel was the cause of the increased waste j volum j SOLID RADIOACTIVE WASTE TOTALS l

1995 1996 1997 Curies 1.826 17.608 90.496 Volume (m2) 45 .9 79 Waste Storage During tours of the radiological controlled area, the inspector confirmed that radioactive l waste was stored in accordance to commitments in Section 11.1.4 of the Fort Calhoun Station Updated Safety Analysis Report. ,

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Waste Stream Samolina In order to classify waste in accordance with 10 CFR 61.55, the licensee implemented a program requiring the periodic sampling and analysis of waste streams to establish correlation or scaling factors between the waste stream classification nuclides and

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-4-nuclides which can be more easily measured using gamma spectroscopy technique ,

The program used the elements described in the NRC's waste classification technical I position paper. The dry active waste stream was to be sampled annually. Resin and filter waste streams were to be sampled before each shipment of wast Technical Specification 5.8.1 requires written procedures and administrative policies be established, implemented, and maintained that meet or exceed the minimum requirements of Sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33. Appendix A of USNRC Regulatory Guide 1.33 includes procedures for the solid waste system. Procedure RW-221, "10 CFR 61 Sampling,"

Revision 3, addresses solid waste and establishes requirements for waste stream sampling. Section 7.9.1 requires that annual samples be taken of the dry active wast Section 7.6 states that annual samples should be collected and sent off site for analysis approximately 9 months after the date of return of the most recent annual sample results from the off-site laborator Laboratory analysis records confirmed that the licensee collected dry active waste stream samples and submitted the samples to an off-site laboratory for analysis in June 1995; the laboratory reported the results in August 1995. The licensee collected dry active waste stream samples next in August 1997; the results were reported in January 1998. However, no records were available to confirm that samples were collected in 1996. The cognizant radwaste operations technician acknowledged that dry active waste stream sampling was not conducted in 1996. The radwaste operations technician also stated that no tracking mechanism was used to ensure that waste stream sampling was conducted. The inspector identified the failure to collect dry active waste stream samples annually as the first example of a violation of Technical Specification 5. CFR Part 20, Appendix G Section Ill.A.3, requires any licensee who transfers radioactive waste to a land oisposal facility or a licensed waste collector to conduct a quality assurance program to assure compliance with 10 CFR 61.55 and 61.56. The licensee's procedures implennnt this requirement. Procedure RW-221, Section 7.15.1, requires licensee personnel ta compare the off-site laboratory analysis with the site gamma isotopic analysis to unsure the results are consistent. In part, it requires verification that cobalt-60, cesium-137, and cerium-144 are within expected levels. The procedure also instructs licensee personnel to note the absence or presence of radionuclides. The procedure requires that documentation generated during the review be maintaine Through personnel interviews and records review, the inspector determined that, for the dry active waste stream, the off-site laboratory analysis was not compared with site gamma isotopic analysis to ensure consistency. The comparison was not conducted between the 1995 analyses or any subsequent analyses of dry active waste stream i samples. The inspector identified the failure to compare off site and licensee analyses as a second example of a violation of Technical Specification 5.8.1.

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l-5-Procedure RW-221, Section 7.16, includes additional quality assurance instructions.

I Section 7.16.2 requires the licensee to compare the most recent annual waste stream sample analysis with the previous annual analysis to identify new radionuclides and to l determine if scaling factors had changed by a factor of greater than 1 Through personnel interviews and records review, the inspector determined that the most recent annual dry active waste stream sample results were not compared with the previous annual results. As in the previous discussion, this quality assurance comparison was not conducted using the 1995 analysis or any subsequent analysis of the dry active waste stream. Had the licensee met either of the quality assurance l requirements of RW-221, Section 7.15 or 7.16, licensee representatives would have identified that dry active waste stream sampling had not been performed in 199 The inspector identified the failure to compare the most recent annual waste stream sampling analysis results with the results from the previous year as a third example of a violation of Technical Specification 5. Procedure RW-221, Section 7.16.3, requires the licensee to update scaling factors, using the latest analysi A review of the scaling factors used by the licensee to relate the abundances of hard to measure radionuclides to the abundances of more easily measured radionuclides confirmed that the licensee had not revised the scaling factors since 1995. The cognizant radwaste operations technician stated that the 1997 sampling results did not appear to provide information in a usable form because the sampleu evidently were counted individually, rather than as a composited sample. Additional samples were not I

taken to compensate for what the licensee representatives considered poor informatio The failure to update the scaling factors is significant because the licensee had leaking fuel elements. Such circumstances could affect the abundances of radionuclides assumed by the licensee and cause incorrect classification of wast The inspector identified this as a fourth example of a violation of Technical Specification 5.8.1 (50-285/9816-01).

The radiation protection manager stated at the exit meeting that licensee's representatives will review the 1997 dry active waste sample results to determine if it is statistically significant and representative of plant conditions. Then the overlooked quality assurance steps would be performe Waste Classification The licensee did not use a commercially-available computer software code to perform the calculations necessary to classify radioactive waste. Calculations were performed manually. The resulting waste classifications were recorded properly on the shipping manifests; however, some of the waste classificatbn work sheets were missing from the shipping documents. (See Section R3.) Using shipment-specific sample analyses, the radwaste operations technician and the inspector recreated some missing classification

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l-6- I worksheets and verified that the corresponding waste shipments of resins and filters l were properly classified, in accordance with 10 CFR 61.5 Waste Manifests The inspector confirmed through random reviews of shipping documentation that the licensee prepared manifests that included the information required by 10 CFR Part 20, Appendix G. Copies of the manifests were forwarded to the intended recipients One copy of the manifest was included with each shipment. Conclusions Four examples of a violation of Technical Specification 5.8.1 were identified related to the solid radwaste management program because waste st., am sampling and internal quality assurance procedures were not implemented properl R1.2 Transportation Activities i

! Insoection Scoce (86750)

The inspector interviewed licensee personnel and reviewed selected examples of the l following:

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= Radiation and contamination sunteys of packages and vehicles

. Shipping paper documentation

. Package marking and labeling

. Vehicle placarding

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Driver instructions l . Notifications to state agencies

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. Emergency response information Observations and Findinas l

Radiation Survevs l Radiation surveys were conducted properly to ensure external radiation and

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contamination levels were within the allowable limits of 49 CFR 173.441 and 173.44 Survey documentation is discussed in Section R3.

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Packaa_e Markina_ and Labelina Shipping documentation indicated that packages were properly marked and labeled. No observations were possible because no shipments were prepared or conducted during the inspectio _

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Activity Limits for Packaoes Shipping records documented that, except for low specific activity material and surface l

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contaminated objects, Type A packages did not contain quantities of radioactive material

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greater than the A, or A, values listed in 49 CFR 173.435. All comparisons were

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conducted manually; no computer codes were used. The activity within shipments of low specific activity and surface contaminated objects did not exceed the conveyance activity ,

limits of 49 CFR 173.427, Table '

Placardina l Vehicle placarding was not observed.

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Good performance was noted in the radioactive materials transportation progra Packaging was correctly chosen, surveyed, marked, and labeled.

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R3 Radiation Protection and chemistry Procedures and Documentation The inspector identified irregularities in the shipping documentation, indicating a lack of j formality in the program. Examples included:

l . Missing waste classification work sheets (FC-RW-218-1, FC-RW-218-4, and l

FC-RW-218-5) were not available to show the basis for waste classification for some shipments, (specifically Shipments 98-02,98-08,98-22). The inspector l- and the radwaste operations technician verified that waste shipments in the corresponding shipments were proper!y classified.

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. The survey results for Shipments 97-29, 97-31, and 97-33, did not indicate all ( distances at which radiation measurements were taken. The radwaste l operations technician confirmed that the measurements were intended to confirm compliance with 49 CFR 173.441.

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. The DOT quantification worksheet (FC-RW-219-1) was not completed correctly l for Shipment 98-02. It indicated the shipment was a Type A quantity instead of a

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Type B quantity. However, the inspector confirmed that an improper shipping l

container was not chosen as result of the incorrectly completed paperwork.

I . There was no justification for the final curie amount assumed for Shipment 98-02, a spent resin shipment. The inspector confirmed the licensee made a conservative adjustment by assuming a higher activity than indicated by sampling L results. However, the basis for the decision was not documente . Form FC-RW-218-1 listed scaling factors that were no longer valid. The cognizant radwaste operations technician stated that this form was no longer used.

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-8-l l Conclusions Documentation associated with solid radwaste management and transportation activities were insufficient to demonstrate the bases for some licensee decisions. Some records

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R5 Staff Training and Qualification t Insoection Scoce (86750)

The inspector interviewed training representatives and reviewed the following:

. Training records

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Radioactive material transportation training outline b. Observations and Findinas The licensee provided training every 2 years in the Department of Transportation and NRC regulatory requirements, the waste buriallicense requirements, and instructions and operating procedures to all personnel involved in the transfer, packaging, and transport or radioactive materia Conclusions Proper training was provided to radiation workers and to specialists that were involved in the transfer, packaging, and transport of low-level radioactive waste and radioactive materia R7 Quality Assurance in Radiation Protection and Chemistry Activities Insoection Scoce (86750)

The inspector interviewed licensee personnel and reviewed the following:

. Licensee's response to NRC Bulletin 79-19

. Quality assurance audits

. Auditor qualifications

. Quality control reviews

. Self-assessments

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-9- 1 l Observations and findinas Solid Radwaste and Transportation Oversicht Since the previous NRC inspection of this area, the licensee conducted one audit that reviewed both the solid radwaste management program and the radioactive transportation activities. The audit was conducted January 7-21,1997. Licensee I representatives stated that the audit of these areas was conducted bienniall The inspector reviewed the licensee's response to NRC Bulletin 79-19, dated September 21,1979, and noted that the licensee responded that quality assurance audits of all transfer, packaging, and transport activities would be conducted annuall During the inspection, licensing representatives were unable to find documentation of a change to this commitment or determine when the biennial audit frequency was implemented. Licensee representatives speculated that the change in audit interval may have resulted when the process control program audit interval was increased to 2 years through the Technical Specification amendment process. The inspector respanded that the process control program, as described in Section 11 of the Updated Final Safety Analysis Report and Procedure RW-200, " Process Control Program, " Revision 3, did not I address requirements for transfer, packaging, and transport activities as referenced in the licensee's response to NRC Bulletin 79-19. Therefore, changes in the auditing i frequency of the process control program were irrelevant. The question of whether the licensee failed to meet a previous commitment involving audit frequency of transportation activities is an unresolved item pending the licensee's attempt to locate the documentation that authorized the change (50-285/9816-02).

The 1997 audit team included a radwaste-shipping, technical specialist from the licensee's organization. The audit team concluded that the solid radwaste management and transportation programs were effectively implemented but identified that Section 11 of the Updated Safety Analysis Report did not accurately describe the process control program, as implemented. The radiation protection organization responded promptly to I i address the audit findings No surveillance were performed in either of the inspection areas; however, quality control personnel conducted second-person verifications of selected aspects on all radioactive transportation activities. Quality assurance representatives stated the reason for limited oversight of these program areas was that the quality assurance {

auditor primarily responsible for review of the radiological controls activities had been j either ill or on disability leave since September 1997.

l i Vendor Oversiaht l Ana'yses of waste stream samples were performed by two off-site (vendor) laboratorie One of the off-site laboratory's operations was reviewed as part of the licensee's vendor audit ng program. The other operations were not reviewed because the contract with the ,

vender was terminated after 2 years. The licensee reviews vendor operations every j

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3 years. The results of the latest vendor audit indicated no problems that would prevent the remaining vendor from providing accurate ana!yticalinformation.

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[ Management oversight of the solid radwaste management program and radioactive f transportation activities was minima An unresolved item was identified, pending the licensee's attempt to locate documentation that authorized a change from annual to biennial audits of the radioactive materials transportation progra y. Manaaement Meetinas l X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on July 10,1998. The 1;censee acknowledged the findings presented. No j proprietary information was identifie l l

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I ATTACHMENT )

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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Breuer, Radwaste Operations Technician J. Chase, Plant Manager S. Gambhir, Division Manager, Engineering and Operations Support G. Gates, Vice President S. Gebers, Manager, Radiation Protection D. Spires, Manager, Quality l

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W. Walker, Senior Resident inspector j l

INSPECTION PROCEDURES USED 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED. CLOSED. AND DISCUSSED OD911 /9816-01 VIO Failure to follow procedural guidance related to waste stream sampling 50-285/9816-01 URI Failure to follow a commitment related to auditing frequency Closed Discussed t

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-2-LIST OF DOCUMENTS REVIEWED l l

Fort Calhoun Response to NRC Bulletin 79-19 I Documents for the following shipments: 97-29, 97-31, 97-33,98-02,98-08,98-22 Waste stream sampling analyses from Barringer Laboratory SARC Audit Report No. 63 (Conducted January 7-21,1997) ,

Procedures RW-200, " Process Control Program," Revision 3 .

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RW-218, "10CFR61 Classification," Revision 6 i l

RW-219, "D.O.T. Quantification," Revision 3 i

RW-221, "10CFR61 Sampling," Revision 3 RW-300, " Shipping Radwaste and Radioactive Materials," Revision 4 RW-304, "Radwaste Shipments to Barnwell, South Carolina," Revision 4

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RW-307, " Emergency Response to Offsite Radwaste and Radioactive Material Transportation Accidents," Revision 4 RW-308, " Response to Lost or Astray Shipments and Shipment Discrepancies," Revision 1

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Forms FC-RW-218-1, " DAW Classification Worksheet," Revision 0 FC-RW-218-2, " DAW Dose Rate to Curie Conversion Worksheet," Revision 3 FC-RW-218-3, " DAW Dose Rate to Curie Conversion Worksheet," Revision 5 FC-RW-218-4, " Classification Worksheet," Revision 0 FC-RW-218-5,'" Classification Worksheet," Revision 0 FC-RW-219-1, " DOT Quantification Worksheet, Revision 2 L