IR 05000312/1986005

Insp Rept 50-312/86-05 on 860116-24.Violation Noted: Failure to Perform Evaluation of Unreviewed Safety Question Per 10CFR50.59(a)

ML20141J059
Person / Time
Site:	Rancho Seco
Issue date:	04/10/1986
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20141J048	List: IR 05000312/1986005 ML20141J043 ML20141J050
References
50-312-86-05, 50-312-86-5, NUDOCS 8604250281
Download: ML20141J059 (15)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /86-05 ,

Docket N License N DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California Inspection conducted: January 16-24 and telephone calls of February 4, 5 and 19, 1986 Inspector: -

9 /8!86 M. Cillis, Radiation Specialist Date Signed Approved By: I k a6s G. P. fuhas, Chief

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Date Signed Facilit'io?s Radiologic al Protection Section Summary:

Inspection on January 16-23 and telephone calls of February 4, 5 and 19, 1986 (Report No. 50-312/86-05)

Areas Inspected: Routine unannounced inspection by a regionally based inspector associated with the control cf radioactive materials and contamination, surveys, and monitoring; lacilities and equipment; transportation of radioactive materials; procedures; audits; radwaste organization and training; receipt of radioactive materials; followup on open items, and a tour of the licensee's facilit Inspection modules 83522, 83526, 83727, 84850, 86721, 92701 and 92702 were performe Results: In the nine areas examined, one violation involving the failure to I perform an evaluation pursuant to 10 CFR 50.59(a) was identified (see paragraph 4).

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8604250281 860411 PDR ADOCK 05000312 G PDR

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DETAILS Persons Contacted Sacramento Municipal Utility District (SMUD) Personnel l

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j *G. Coward, Manager, Nuclear Plant

• S. Redeker, Nuclear Operations Manager

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• R. Colombo, Regulatory Compliance Supervisor

• F. Kellie, Radiation P'rotection Superintendent

*R. Lawrence, Staff Assistant (PASS Project)

• J. Jewett, Site Quality Assurance Supervisor i *J. McCulligan, Assistant. Manager, Nuclear Plant

• J. Shetler, Nuclear Scheduling Manager

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• J. Fields, Technical Support Superintendent

*D. Gardner, Senior Chem-Rad Assistant (SCRA)

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• J. Reese, Plant Health Physicist i *D. Comstock, Assistant Operations Superintendent Marsh, Site QA Nuclear Engineer Turner, Training Superintendent i Thonpson, Training Supervisor Canter, QA Operations Surveillance Supervisor Nuclear Regulatory Commission (NRC)

G. Perez, Acting Senior Resident Inspector Applied Radiological Controls (ARC)

I l R. Rewalt, Supervisor, Senior Radiation Protection Technician R. Synder, Senior Radiation Protection Technician Impell Corporation

• F. Lavely, Health Physicist I * Denotes attendance at exit interview on January 24, 1986.

l! In addition to the individuals identified above, the inspector met with i

and held discussions with other members cf the licensee's and contractors staff.

, Followup on Previous Inspection Findings i (0 pen, 50-312/84-27-01): The status of the Low Level Radioactive I

Waste Storage Facility described in paragraph 2 of Inspection Report 50-312/84-27 was examined.

Construction of the facility was completed during the summer'of

! 1985. Preoperational testing of various systems installed in the i

new facility were in progrere at the time of this inspection. The

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inspector was informed that preoperational testing would be completed during the summer of 1986.

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. _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ ._____________ * 2 Discussions with the licensee's staff indicated that licensee representatives are considering expanding the use of the facility to activities other than discussed and approved in the original 10 CFR 50.59 Safety Evaluation Report. The original 10 CFR 50.59 Safety Evaluation Report indicated that the facility would be used solely for the storage of low level radioactive waste The facility was not approved for performing waste processing evolutions which could result in a release path to the environmen This observation uas discussed with the Nuclear Project Engineer and was brought to the licensee's attention at the exit interview *

(50-312/84-27-01). (Closed) Special (50-312/85-11-S1) Discussions with licensee representatives revealed that Chem-Nuclear System Incorporeted (CNSI) liner, number 436844-3, was dropped on two different occasions on November 26, 1985. The liner which contained spent dewatered secondary resins was dropped by a crane from heights of approximately 0.5 feet and 5.0 feet; respectively, during an attempt to transfer the liner from the resin solidification pa The resin was being solidified in concrete at the time of the occurrence. The liner was moved when the concrete was still in liquid form. A visual inspection of the liner that was mcJe after each occurrence did not reveal any damag The event was documented in accordance with procedure AP-22

" Occurrence Description Report" (ODR) and a investigation of the occurrence was conducted by the licensee's Incident Analysis Group (IAG). The ODR and Lessons Learned Report #85-02 of December 13, 1985 were reviewed. The lessons learned report identified several causes. They are as follows:

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1) The crane's cable had been previously extended to its end on the cable holding drum, and was then subsequently rewound in the reverse direction. This in turn caused the crane to be operated in reverse of its normal condition. This operating mode did not permit the load check device to stop the liner drop ) The crane cable Icngth did not meet ANSI standards or OSHA requirement ) Lack of equipment operator training at the classroom and hands on leve The review disclosed that the licensee's investigation of the root cause associated with event was . thorough and the corrective action proposed appeared to be adequate. This matter is closed (85-11-SI).

3. Control of Radioactive Materials and Contamination, Surveys, and Monitoring An examination was conducted for the purpose of determining the effectiveness of the licensee's program for controlling radioactive

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materials a m contamination. The licensee's survey and monitoring program for assuring compliance with 10 CFR Part 20 was also examine Areas examined were as follows:

Area Radiation and Airborne Radioactivity Monitor *

Portable survey, sampling, and contamination monitoring instrument *

Protective clothing supplie ,

Radioactive material and cortamination contro *

In-Plant surveys and monitorin *

Audits related to the progra ' *

Applicable procedur The examination included:

Discussions with the licensee's staf *

Review of survey records, audit reports, portable radiation monitoring instruments, and Process and Effluent Radiation i

} Monitoring instrument calibration record l l *

Observation of contamination and radioactive material control practice *

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Observation of protective clothing and equipment.

Review of the applicable site procedures related to the above item The inspection disclosed the following:

1 a) Audit and surveillance frequencies have increased and have improved

, in quality over that observed during previous inspections.

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b) Supplies such as portable monitoring equipment, pocket fonization chambers, and protective clothing all appeared to be adequate. The licensee's calibration of portable survey instruments are performed in accordance with procedures that were developed using the recommendations of ANSI N323-197 '

Portable instruments observed during the inspection appeared to be in current calibratio The inspector noted that Portable Constant Airborne Monitors (PCAMs)

are not used at fixed locations throughout the plant even though six (General Atomics (GA)) PCAM's were available for use. This observation was discussed with the Radiation Protection Superintendent, Plant Health Physicist, and at the exit interview.

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The Plant Health Physicist informed the inspector that the six PCAMs i

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were purchased several years ago and were never put into servic He added that an Eberline PING-PCAM had recently been purchased end s

would be put into service af ter it was calibrated. He added that procedures and training for utilizing the FING also had to be developed. The licensee informed the inspector that they would also

look into incorporating the utilization of the'GA PCAM The Plant Health Physicist informed the inspector that an evaluation for improving personnel portal monitoring equipment had been approved by SMUD management. He added that portal monitoring equipment from three different vendors are to be evaluated over the next four months for the purpose of improving their current personnel monitoring progra ! It should be noted that personnel contamination oc-currences may be

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minimized if care is used during the removal of protective clothir l This requires that the clothing be donned in a specific manner. l ae j inspector observed workers entering and exiting from radiologica Of I controlled areas that required cl.e use of protective clothing. The observations revealed that the workers did not don or remove their protective clothing in the same sequence. No instructions for donning or removing the protective clothing are provided by the licensee for assisting workers entering and exiting from controlled areas. This same observation was identified by the licensee's QA surveillance This item was discussed with the Plant Health physicis '

The inspector observed that protective clothing requirements prescribed on Radiation Work Permits (RWPs) were extremely flexibl The options prescribed on an RWP consider contamination levels- and the type of work that the individual performs. An RWP may prescribe

many different combinations of protective clothing requirements than

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one would expect workers to remember. This observation was discussed with the Plant Health Physicist. The inspector pointed

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out that although there are no specific regulatory requirements related to the use of protective clothing, the instructions provided 4 on the RWP's were unclear. The inspector added tnat this may confuse the workers. The inspector stated that this could subsequently lead to RWP violations or an inadvertent personnel

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contamination because a worker did not clearly understand the RWP instructions. This same observation was identified from internal surveillances conducted by the licensee's QA staf ) The inspector noted that current procedures allow materials to be released with 500 counts per minute (cpm) of fixed contaminatio <

This appears to be inconsistent with the recommendations made by IE -

Information Notice 85-92: " Surveys of Wastes Before Disposal From Nuclear Reactor Facilities". This observation was discussed with the plant Health Physicist and Radiation Protection Superintenden The inspector pointed out that the IN states that care should be taken to ensure that no licensed material is released contrary to the provisions of 10 CFR 20.301. The IN also states that: "In practice, no radioactive (license) material means no detectable radioactive material."

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The Plant Health Physicist informed the inspector that normally, material surveyed prior to its release meets the criteria of IN 85-9 The Radiation Protection Superintendent informed the inspector that the IN was just forwarded to him for evaluation and that the evaluation was incomplete at the time of this inspectio He added that the evaluation would be consistent with the recommendations made by the I ) Plant survey and monitoring records appeared to be consistent with 10 CFR Part 20.201, " Surveys" and 20 CFR Part 20.401, " Records of Surveys, Radiation Monitoring, and Disposal".

5) A review of calibration records and procedures associated with area radiatian monitors (ARMS) and Process and Effluent Radiation Monitors (PERM) was conducted. The procedures for calibrating the ARM's appeared to be adequat Procedures for performing calibration of PERMS and establishing and maintenance of PERM setpoints do not appear to provide sufficient detail. This same observation was identified from licensee internal surveillance No violations or deviations were identified. Radioactive Material Receipt and Transportation The inspector reviewed the licensee's radioactive material receipt and transportation program for compliance with the regulatory requirements prescribed in 10 CFR Part 20.205, 10 CFR Part 61,10 CFR Part 71 and 49 CFR Parts 171 through 178 and Regulatory Guides 7.1 through 7.1 Procedures and Management Controls The licensee has developed and implemented procedures for assuring compliance with the above regulatory requirements. The applicable procedures are contained in the licensee's Radwaste Control Manua The following procedures were reviewed:

Procedure Title Re Dated AP.309 ARTICLE 1 AP.309 Radioactive Waste Minitization 1 02-24-86 AP.309 I SHIPMENTS AP.309 I - 1 Determinat}on of the Requirenents 7 02-24-86 for a Ship' ment of Radioactive Material Offsite AP.309 I - 2 Determination of DOT Subtype and Ori Packaging Requirements for Radioactive Materials

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AP.309 I - 3 ClashificationofRadioactive 1 09-20-85 Waste

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AP.309 I - 5 Curie Content Calculation Using 2 11-05-85 Dose to Curie Constants and Scaling Factors AP.309 I - 7 Waste Stream Identification and 1 11-05-85 Sampling AP.309 II IIANDLING AND PAC 3GING

AP.309 II - 1 Resin Dewatering Ori AP.309 II - 2 Radwaste Container Selection and 3 03-03-86 Packaging AP.309 II - 4 Solidification of Resin or Water' 2 08-13-85 Using Cement with Chem-Nuclear Solidification Unit 126 AP. li - II - 8 Routine Handling and Loading of Ori CNSI Cask Model Number CNS 8-120 AP.309 III EQUIPMENT OPERATION AP.309 III - 2 Compactor Operation 2 11-05-85 The review disclosed that the above procedures appeared to provide the necessary instructions for assuring compliance with the NRC and DOT regulations referenced abov The inspector observed that the licensee also maintained current copies of DOT regulations, burial site license, cask user / owner maintenance manuals, and appropriate certificates of compliance (C of Cs) for certain radioactive wastes transport packages (i.e.,

casks) used for Class B waste shipments. '2he *

review indicated that the licensee's Quality Assurance program appeared to be consistent with 10 CFR Parts 71.103 and 71.10 No violations or deviations were identifie Organization Management of transpcrtation activities and the radioactive waste program is under the direction of a Senior Chem-Rad Assistant (SCRA)

who reports directly to the Radiation Protection Superintenden Permanent staffing includes nine utility workers, two Chem-Rad Assistants (CRAs), and two Senior Radiation Protection Technicians from ARC. The two CRAs are rotated at a two to four week interval Responsibilities of the SCRA include: -

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Training of his staff

Preparation and implementation of the Radwaste Ccntrol Manual

Operation of the waste compactor

Operation of the freon / ultrasonic decontamination facilities

Shipment of radioactive meterial/ wastes

Receipt of radioactive material

Cleanup / decontamination activities

Implementation of the Process Control Program

Maintenance of respiratory equipment

Manning and operation of the Low Level Radioactive Waste Storage Facility which is currently under constructio The staff is augmented with ARC contract personnel during repair / refueling outage The SCRA responsible for radwaste management informed the inspector that his time was primarily devoted towards supporting routine plant operations. He added that he had little time to apply towards research and development, development of procedures, and training of the radwagte staff. The SCRA has brought these concern to management on several occasions. He has expressed the need for a dedicated radiation protection staff and a radwaste engineer en provide assistance in maintaining the radwaste program in accordance with the appropriate regulatory requirement The following memorandums related to the SCRA's concerns were reviewed:

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October 30, 1980 " Waste Drum Handling South Hatch" June 16, 1983 " Trip Report on Packaging and Transportation of Radioactive Waste Material June 7-9, 1983" August 16, 1983 "10 CFR 61 Compliance" August 17, 1983 " Filter Modifications" August 26, 1983 "10 CFR 61, 10 CFR 20.311, 49 CFR Compliance Radioactive Waste" December 2, l')83 "Solidifications of Radioactive Filters" February 6,1984 " Waste Management - Your Memo of 1-5-84" March 6, 1984 " Inability to Stabilize Radioactive Waste" April 30, 1984 " Request for Radwaste Management Assistance Under Contract 9851" September 4, 1984 " Crud Tank Filters" I

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November 21, 1984 " Movement of Radiation Waste Barrels From j the Waste Gas Compressor Room 6&7, I November 1984" December 20, 1984 " Packaging of Waste Class B&C Cartridge Filters"

+ May 7, 1985 " Disposal of Crud Filters" '

The memoranda were prepared by the SCRA responsible for managing the

! radwaste program. They identified a variety of problems associated with tile licensee's radwaste progra The memos revealed that the need for providing a dedicated radwaste engineers to augment the

radwaste program had been brought to managements attention. One 1 example; is the methodology currently utilized for the use and removal of crud filters. The memoranda pointed out that with

engineering assistance the methodology for installation, removal, and shipment of the crud filters could be greatly simplified. The simplification would result in a sizeable cost savings and an exposure reductio The SCRA's concerns were discussed with the Radiation Protection Superintendent (RPS) and brought to the licensee's attention at the exit interview. The RPS and Plant Manager informed the inspector that improvements in this area were underway. This same finding had been brought to their attention by two other independent sources'.

The Radiation Protection Superintendent and Plant Manager informed the inspector that a major reorganization of the radiation protection group was currently in progress. The reorganization is

' expected to provide the plant's radwaste group with dedicated 1 radiation protection technicians and technical support personne The RPS and Plant Manager added that engineering support of the l radwaste program may be augmented; as necessary, with the use of system engineers from the sites engineering staff or with contractor personnel. This item will be examined during a subsequent incpection (50-312/86-05-01).

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j Inspection Report 50-312/84-27 identified weaknesses with the licensee's radwaste management training program. No significant changes to the training program for personnel involved in the licensee's radwaste management program had been developed since November of 1984. A formal training program for radwaste handlers has not been developed. Most of the training conducted _has

essentially been on-the-job trainin The above concerns were also identified in a recent QA audit l conducted in November 1985. The inspectors concern and the findings documented in Audit Report No. 0-754 of November 8, 1985, were discussed with the Training Superintendent and' Training Superviso l l

The Training Superintendent informed the inspector that the training l program for radwaste handlers would be evaluated. The SCRA l l

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responsible for radwaste management program agreed that improvements

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in training of radwaste handlers was needed. Both the Training Manager and SCRA agreed to join their efforts for the purpose of ,

improving the training progra No violations or deviations were identifie CFR Part 61 and 10 CFR Part 20.311 Compliance The licensee's program for assuring compliance with 10 CFR Part 61,

" Licensing Requirements for Land Disposal of Radioactive Waste" and 10 CFR Part 20.311, " Transfer for Disposal and Manifests" was examined.

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The examination disclosed that procedures have been developed and

implemented for the purpose of determining radioactive waste l classifications and characterizetion pursuant to 10 CFR Parts 61.55

! and 61.56. The classifications are based on:

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Concentration of both long and short term radionuclide *

The wastes form and characterizatio The procedures also address:

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Waste Shipment Labeling

Disposal Site License Conditions

Waste Manifests

Tracking of Waste Shipments The licensee's program for waste stream identification and sampling has been in existence for approximately two years. Normally seven vaste streams are sampled annuall The seven waste streams are:

evaporator bottoms, reactor coolant, reactor coolant solids (crud),

smears of dry active waste, smears of filter cartridges, oils, and ion exchange resins. The samples are submitted to s; offsite laboratory for analysis. Annual scaling factors are developed from this process which are then used for waste classification. Periodic sampling (e.g. quarterly) from the waste streams is conducted for assuring the annual scaling factors have not changed significantly

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performed for any significant changes. The' licensee's method for accomplishing the periodic verifications of the scaling factor is performed by comparing Cobalt-60/ Cesium-137 ratio to the annual result A review of the scaling factors developed from the 1984, 1985 and periodic verifications was conducte It appeared that no major

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changes in plant conditions occurred between sample !

In conclusion, it appeared that the licensee's program was

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consistent with 10 CFR Part 20.311 and 10 CFR Part 6 No violations or deviations were identifie ,

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E. Procurement and Reuse of Packaging The licensee's program tor procurement of packaging selected for shipping radioactive material was examine Discussions with the SCRA responsible for radwaste management program and a review of procedure AP 309 II-2, "Radwaste Container Selection and Packaging" revealed that the licensee's program for selecting packaging used for radwaste shipments appears to be consistent with 10 CFR Part 71 and 49 CFR Part 17 No violations or deviations were identifie F. Waste Handling Facilities The inspector toured the current out door vaste storage area and the new low level radioactive waste storage facility discussed in paragraph 2 of Inspection Report 50-312/84-27 and paragraph 2.A of this repor It should be noted that 10 CFR Part 50.59 requires:

"550.59 Changes, tests and experiment (a)(1) The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report, and (iii) conduct tests or experiments not described in the safety analysis repert, without prior Commission approval, unless the proposed chat.ge , test or experiment involves a change in the technical specifications incorporated in the license or an unreviewed safety questio (b) The licensee shall maintain records of changes in the facility and changes in procedures made pursuant to this section, to the extent that such changes constitute changes l'n the facility as described in the safety analysis report or constitute changes in procedures as described in the safety analysis report. The licensee shall also maintain records of tests and experiments carried out pursuant to paragraph (a) of this section. These records shall include a written safety evaluation which provides the bases for the determination tha't the change, test or experiment does not involve an unreviewed safety question..."

The site plan, as defined by Technical Specifications, Section 5.1, 13 shown on Figure 1.1-2 of the FSAR. Figure 1.1-2 shows an outdoor radwaste storage area is located approximately 25-50 yards west of the hyp'erbolic cooling towers. Figure 11.1-7 of the FSAR shows that solid wastes are packaged / processed and then moved to the temporary storage area prior to offsite shipment. The storage area is also described in Section 11.1.5.1 and Figure 1.1-3 of the FSA Section 11.1.5.1.3 describes the area on Figure 1.1-3 as an area for the storage of solid wast .

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The inspector observed that a temporary wooden structure was constructed in the outdoor radwaste storage area. Discussions held with the SCRA responsible for radwaste management revealed that the structure had been constructed sometime between June and September

! 1985. He added the facility was used on a temporary basis since its-construction. He added that it will be.used until low. level radwaste storage facility described in paragraph 2 of Inspection Report 50-312/84-27 becomes available for use. The SCRA added that I the contents of containers being prepared for shipment were being inspected in the facility. Other operations performed in the facility include optimization of container useable volumes. This may involve the consolidation of other low level radwaste to fill

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l void spaces of the containe Other routine packaging inspections are performed for assuring regulatory compliance for disposal of radwaste prior to shipment. The facility was also used to cut up crud filter outer container i The structure is built of 2 x 4's with 16" centers and 3/8" plywood for the exterior. Two 10' x 10' steel rollup doors are employed to provide for a contamination control boundary. The majority of the flooring is composed of 2 x 4's and plywood. All exposed wood is coated with fire resistant pain The facility is equipped with a 500 cubic feet per minute HEPA filter exhaust system. A structure built of scaffolding pipe and herculite was used for a six to eight month period prior to erecting the plywood structure. The pipe and herculite structure was used in the same manner that the plywood l structure is currently used.

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! A review of survey records taken in the facility disclosed that all i operations performed in the building were monitored as prescribed in the licensee's Radiation Protection Manual. Contamination levels

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for the operations performed in the facility ranged from non

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detectable levels to 2.0E5 dpm/100 cm2. Airborne contamination sampling taken indicated levels ranging from 5.5E-10 to 1.8E-11 l microcuries per milliliter (uCi/ml).

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t The examination discloced that the structure is not shown or described in the License and FSAR. No specific guidelines were

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established for the facility that defined the limitations on its utilization under normal and emergency conditions associated with plant operations. An evaluation, pursuant to 10 CFR Part 50.59, to ascertain if an unreviewed safety question existed or if a change to the Technical Specifications was needed had not been conducte This was brought to the licensee's attention on January 18, 198 The inspector was provided with a copy of a Safety 2 valuation

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Report, Log No. 736, that was conducted by the licensee on January 22, 198 '

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The licensee was informed that failure to perform a safety evaluation review pursuant to 10 CFR Part 50.59 was considered as an apparent violation (50-312/86-05-01). The inspector added that no response was necessary in view of timely manner the item was corrected.

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G. Transportation Incidents 1) General Discussions with licensee representatives revealed that with the exception of failure to complete shipping labels properly no specific transportation incidents occurred during the period of January 1985 through January 1986. A total of 117 shipments of radioactive material / wastes were made during this perio The event involving failure to properly complete shipping labels is described in paragraph 2 belo ) Incomplete Labeling J

Licensee representatives disclosed that a Type B CNSI 8 120 cask loaded with an encapsulation liner containing 240 Curies of spent filter cartridges was shipped frem Rancho Seco on December 5, 1985, with incomplete information on required Department of Transportation shipping label The SCRA informed the inspector that during a review of Radioactive Waste Shipment 85-86 shipping manifest he was unable to verify if the information required had been entered on the affixed Yellow II labels as required by 49 CFR 172.403(c) of Subpart E. The driver of the vehicle was contacted before the shipment reached its final destinatio The driver confirmed the SCRA's concerns that the information required to be included on the labels had been omitted. The driver was instructed to put the proper information on the label and tFen the shipment was allowed to proceed to its final destination. The inspector noted that all of the other required information on the manifest appeared to be consistent with the appropriate NRC and DOT requirement The licensee documented the event on an ODR and is currently evaluating methods for preventing a recurrence of this inciden No violations or deviations were identifie H. Radioactive Material Shipment and Receipt Ten percent of the licensee's radioactive material shipment and thirty percent of radioactive material receipt records for the period of January 1, 1985 through January 23, 1986 were reviewed. A total of 117 radioactive material / wastes shipments were made during this period and a total of 20 shipments were received during the perio Documents addressing quantity, compliance with 49 CFR 100-199, surveys, shipment checklists, package and vehicle marking / placarding, loading and state agency notifications were examine ,

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Four shipments involved the transportation of Class B waste Remaining transportation activities were categorized as Class A shipments. The cask used for the Class B shipments was a CNSI Model 8, CNS 8-120 shipping package. A copy of the approved

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Certificate of Compliance, No. 6601, Revision 19 for the cask was

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reviewed and found to be in compliance with the appropriate regulatory requirement The v.olume of radioactive wastes shipped during this period was approximately 35,000 cubic feet. The material primarily consisted of:

Solidified secondary resins

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Primary resins

Boxes of packaged material

Barrels of packaged material

Evaporator bottoms

Spent filters (mechanical)

The major ontributors towards the 35,000 Ft were the evaporator bottoms, secondary resins, barrels, and boxes. The large volume was an accumulation of material that was generated over the past several years. The.SCRA expects the volume will decrease in 198 The receipt of radicactive material by the licensee's staff appeared to be consistent with 10 CFR Part 20.20 No violations or deviations were identifie <

I. Quality Assurance / Quality Controls An examination was conducted to determine if Quality Assurance (QA)

and Quality Control (QC) programs were established for assuring compliance with the regulatory requirements prescribed in 10 CFR Part 20.311, 10 CFR Part 61, 10 CFR Part 71 and Department of Transportation (DOT) regulatory requirements prescribed in 49 CFR

, Parts 171-17 Region V Inspection Report 50-312/84-27, Paragraph 3.D identified weaknesses with the licensee's QA/QC programs. This finding was also identified by licensee internal and external audit Quality assurance audit and surveillance reports associated with radioactive material receipt and transportation activities accomplished since January 1985 were reviewed during the inspectio The review of the QA records revealed that the QA audits and surveillances appeaced to be vastly improve More frequent audits and surveillances of waste management activities are being conducted. The selection, qualification, and experience level of the QA staff resp'onsible for performing audits and surveillances of waste management activities was consistent with ANSI 45.2.23, " Qualifications of Quality Assurance Program Au'dit

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Personnel for Nuclear Power Plants". The audits and surveillance performed by the QA staff appeared to be comprehensive. A recent QA audit of the radwaste program identified that improvements in developing an independent QC program need to be established. A SMUD letter, HLC 86-014, of January 14, 1986, disclosed that the site QA operations surveillance group will develop a QC inspection program by March 1, 1986, and train QC personnel by April 1, 1986. When implemented this independent QC program will improve the licensee's current QC program for radwaste managemen The inspector concluded that the licensee's QA/QC program for radwaste management appeared to be consistent with 10 CFR Part 20.311(d)(3).

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No violations or deviations were identifie t Exit Interview The inspector met with the licensee's representatives (denoted in paragraph 1) at the conclusion of the inspection on January 24, 198 The scope and findings of the inspection were summarized. The licensee was informed of the violation discussed in paragraph 4. The inspector emphasized the following areas requiring licensee attention:

a) Providing an adequate staff and technical support for control of radwaste activitie b) Developing and implementing a formal training program for the radwaste organizatio c) Ensuring that the use of the new low level radwaste storage building (see paragraph 2(A)) does not result in a violation of 10 CFR Part 50.5 The Plant Manager informed the inspector that the radiation protection group was being reorganized. He expects the reorganization will address the concerns related to staffing and technical support of the radwaste grou .

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