IR 05000382/1994017

Insp Rept 50-382/94-17 on 940718-22.No Violations Noted. Major Areas Inspected:Solid Radioactive Waste Mgt & Radioactive Matl Transportation Programs

ML20149F134
Person / Time
Site:	Waterford
Issue date:	08/01/1994
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20149F113	List: IR 05000382/1994017 ML20149F109
References
50-382-94-17, NUDOCS 9408100012
Download: ML20149F134 (9)

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l APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report: 50-382/94-17 License: NPF-38 1 Licensee: Entergy Operations, In P.O. Box B Killona, Louisiana Facility Name: Water #ord Steam Electric Station, Unit 3 Inspection At: Taft, Louisiana Inspection Conducted: July 18-22, 1994 Inspector: Anthony D. Gaines, Radiation Specialist Facilities Inspection Programs Branch Approved: //Lft E d(.ff 686/

. Murray, Chief,LFacilitic Inspection Date' /

Programs Branch Inspection Summary V Areas Inspected: Routine, announced inspection of the solid radioactive waste management and radioactive materials transportation program Results:

• Very good audits and surveillances were performed by qualified individuals (Section 1.1).

. There had been no major changes in facilities, equipment, programs, or procedures (Section 1.2).

. The radioactive waste and transportation programs included a well qualified staff (Section 1.3).

• An excellent training program had been implemented for personnel involved in transportation activities. The licensee committed to revise a training procedure in order to satisfy their response to NRC Bulletin 79-19 (Section 1.3).

• Good implementing procedures were maintained for the radioactive waste management program (Section 1.4).

9408100012 940004 PDR O ADOCK 05000382 PDR

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• Onsite radioactive waste in storage was shipped in anticipation of the closure of the offsite burial site (Section 1.4).

• Radioactive waste was properly classified, characterized, and prepared for shipment (Section 1.5).

• Individuals responsible for transportation of radioactive waste were knowledgeable of the regulatory requirements and burial site license conditions (Section 1.6).

Attachment:

• Attachment - Persons Contacted and Exit Meeting

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-3-DETAILS 1 SOLID RADI0 ACTIVE WASTE MANAGEMENT AND TRANSPORTATION OF RADI0 ACTIVE MATERIALS (86750)

The inspector reviewed the licensee's radioactive material transportation program to deterrrine agreement with the commitments made in response to NRC Bulletin 79-19; compliance with the requirements of 10 CFR Parts 20, 30, and 71; and 49 CFR Parts 171 through 189. The inspector also reviewed the licensee's program for processing, control, and onsite storage of solid radioactive waste for agreement with the commitments in Chapter 11.4 of the Final Safety Analysis Report and compliance with the requirements in Technical Specification 6.8; and 10 CFR 61.55 and 61.5 ,

1.1 Audits and Appraisals The audit frequency for the solid radioactive waste and transportation programs was biennia Therefore, there had not been a comprehensive audit performed since the last inspection of this area in June 1993 which reviewed the audit performed March 5 through April 7, 1993. However, there were other specialized audits of plant wide programs that were performed that included areas in the solid radioactive waste and transportation of materials pregram The inspector reviewed the following: a draft audit report of an audit conducted May 9 through July 5, 1994, titled " Performance, Training, and Qualifications," which included a review of radwaste personnel training; an audit conducted June 29 through August 31, 1993, titled " Procedure Revision i Process / Instructions, Procedures, and Drawings," which included a review of the Radwaste Department's methods for revising procedures; and an audit conducted February 11 through May 9, 1994, titled " Computer Codes and Software," which included a review of the vendor supplied computer program Radman that the Radwaste Department used for transportation purposes. The audits reviewed were very good and pertinent items were included in the licensee's self-assessment program. Corrective actions for audit findings were appropriate and timel Surveillance reports of quality assurance activities performed since the last inspection of the solid radioactive waste and transportation programs in June 1993 were reviewed for scope, thoroughness of program evaluation, and timely followup of identified deficiencies. The inspector reviewed the quality assurance surveillances performed during the period June 1993 through July 1994 in the areas related to the performance of the solid radioactive waste and transportation programs. Comprehensive quality assurance ,

surveillances were performed by qualified individuals to evaluate program '

activities and provided a means for periodic management oversight. The surveillances did not indicate any aoverse finding The licensee used a vendor to conduct radiochemical analysis required in 10 CFR Part 61. The inspector noted that the vendor was on the licensee's Qualified Seppliers List. The licensee used an audit performed by another utility in March 1993 to maintain the vendor on the quhlified lis The inspector noted that the licensee had reviewed the audit of the vendor for appropriateness to their program. Also, the licensee's personnel performed a

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l vendor audit of the company that distributes and supports the Radman computer program used by the Radwaste Department to ship radioactive waste. The vendor '

audit was performed March 30-31, 1993, and identified pertinent findings and observations. The licensee tracked the findings and observations to ensure that appropriate corrective actions were taken by the vendo The inspector reviewed selected Condition Reports that pertained to the solid !

radioactive waste and transportation programs. The inspector noted that they were handled appropriately, and corrective actions had been taken. The responses to corrective actions were noted to be timely, except for one. The inspector asked about the timeliness of the response and was informed that the reason that the response did not appear to be timely was that the scope of the corrective actions was increased part way through the originally allotted response time, which caused the response to be overdu :

1.2 Changes j The inspector reviewed the organization, management controls, staffing, and !

the assignment of solid radioactive waste and transportation program responsibilities for changes. The inspector noted that there had been no  ;

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major changes in facilities, equipment, programs, and procedures that would have adversely affected the solid radioactive waste management and transportation of radioactive materials programs since the last inspectio ;

i The inspector noted that only minor organizational changes had been made to ,

the program. The changes in the Radwaste Department included the upgrading of i a deconner position to that of a health physics technician positio This was t a very good change that added some technical depth to the departmen It was I also noted at the time of the inspection that the position was vacant. The !

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individual that occupied the position accepted a promotion at another Entergy plant. The licensee was reviewing the vacancy to determine whether the  ;

position would be fille l Only minor changes to procedures were noted. The majority of the changes were !

in response to the title of the head of the Radwaste Department changing from j Radwaste Supervisor to Radwaste Forema i 1.3 Training and Qualifications

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The inspector reviewed the training and qualification programs for personnel responsible for implementing the solid radioactive waste and transportation of radioactive materials programs. The licensee has established a good training program. The inspector discussed radioactive waste training and lesson plans :

with the radioactive waste instructor. The qualifications of the instructor were reviewed and found to be appropriate. The instructor had recently i attended a vendor's radioactive waste and shipping course for training i personne l t

The inspector reviewed initial and continuing traini g irovided to radioactive i waste personnel and noted that it was appropriate, lhe inspector noted that ;

all of the radwaste personnel had attended a vendor taught transportation ,

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-5-training course and met the licensee's required qualification The Radwaste '

Foreman had attended appropriate training within the last yea The instructor mentioned to the inspector that for 1994, the licensee planned to have the Radwaste Foreman and designated personnel attend a vendor ,

transportation course and a Radman computer course, instead of providing the training to all radwaste personnel as had been the practice in the pas The inspector noted that most of the personnel that had taken the vendor course ,

annually were decor personnel, who were not directly responsible for the shipping and transportation of radioactive waste. A review of the licensee's response dated June 16, 1983, to NRC Bulletin 79-19, " Packaging of Low-Level Radioactive Waste for Transport and Burial," stated that training and periodic retraining of radwaste personnel involved in the transfer, packaging, and transport of radioactive materials would be accomplished in accordance with Radwaste Procedure RW-1-410, "Radwaste Personnel Qualifications." The procedure did not require radwaste helpers (decon personnel) to have the type of vendor training that had been provided to them annually. Therefore, the past practice of providing the training to all radwaste personnel was beyond the licensee's commitment to NRC Bulletin 79-19. The procedure specified the positions and the training requirements for each position. The inspector noted that the procedure had been deleted in 1985, and the contents were switched to the licensee's training manual. The inspector reviewed the corresponding procedures in the training manual and noted that the training procedures did not detail, as the previous procedure had, the positions (personnel) which required training in response to NRC Bulletin 79-19. This was discussed with the licensee and, before the exit meeting, the licensee revised the procedure for initial training of radwaste personnel to indicate the positions that required the training in response to NRC Bulletin 79-1 However, the inspector noted that the procedure for periodic retraining of radwaste personnel had not been revised. This was discussed with the licensee and, at the exit meeting, John Houghtaling, the Technical Services Manager, committed to revise Training Procedure NTC-238, "Radwaste Services Continuing Training," to iriclude the radwaste personnel required to attend periodic training in response to NRC Bulletin 79-1 .4 Solid Radioactive Waste Management The inspector reviewed selected radioactive waste procedures that implemented the licensee's solid radioactive waste management program. The inspector noted that good quality procedures had been established for the processing and disposal of low-level radioactive waste, and the procedures met the requirements of the licensee's Technical Specification t The licensee had shipped for burial the majority of radioactive waste onsite before the burial site was closed to them on July 1, 199 As part of the licensee's long-range radwaste management plan, the licensee had been keeping abreast of the burial site development in their compact and have reviewed their storage capabilities. The licensee estimated that they have approximately 12 to 18 months of onsite space for generated radioactive wast The licensee's review of the burial site development indicated that their compact may not have a burial site for 5 years or mor Therefore, the licensee had been designing an onsite storage space for the amount of

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-6-radioactive waste that they would generate in 5 years with the possibility of future expansions of another 5 years' inventory of radioactive waste. The licensee plans to have the design completed by September 1994, and the ,

building finished by July 1995. The licensee had not completed a 10 CFR 50.59 '

review or changes to their Final Safety Analysis Report for the building; therefore, these items will be reviewed during a future inspectio .5 Radioactive Waste Classification. Waste Characterization, and Shipping Reauirements ,

The inspector reviewed the licensee's radioactive waste procedures and found i the licensee's program for classification and characterization of radioactive waste to meet the requirements of 10 CFR Part 61. The licensee and a

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contractor laboratory performed radiochemical analyses on samples of various radioactive waste types as required in 10 CFR 61.55 and 61.56. The inspector noted that the sample analyses had been completed at the proper frequenc The test sample analyses results were used for determination of radwaste classification and radionuclide composition of the radwaste sources. The licensee performs radionuclide analyses for radionuclide characterization on radioactive waste packaged for shipment and burial and employs correlation factors for characterization of radionuclides not directly identifie The inspector reviewed selected radioactive waste shipment manifests and shipping papers that accompanied the licensee's shipments of radioactive waste. The inspector determined that the completed manifests complied with the requirements of 10 CFR 20.200 .6 Transportation Activities The inspector reviewed the licensee's transportation program for shipment of radioactive materials and radioactive wast . Quality A.ssurance Program The licensee had maintained an approved (Approval 0604) quality assurance program in accordance with 10 CFR Part 71, Subpart H, for the transportation of radioactive materials. The approval expires June 30, 199 . Procurement and Selection of Packages The licensee used strong-tight containers for the shipment of radioactive waste. Most of the shipments were in sea / land containers which contained uncompacted waste that was shipped to vendors who segregated and repackaged the radioactive waste. Other shipments included laundry shipments in steel containers and shipping casks with spent resin in high integrity container The licensee was on the user's list for all NRC and DOT certified packages use The licensee maintained current documentation on the manufacturer's design testing, maintenance, and the NRC Certificate of Compliance for all radioactive material packages used by the license /' . .

-7-1. Preparation of Packages for Shipment The inspector verified that the licensee had procedures and checklists for the preparation of radwaste shipment These 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 ,

determination of radiation and contamination limits. The licensee used a checklist to assure that the procedures were followed and that packages were properly prepared for shipment in accordance with NRC, DOT, state, and burial i site requirements. Discussions with licensee personnel indicated that the individuals involved in the transportation of radioactive waste and materials '

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possessed a good knowledge of the procedures and NRC and DOT regulations pertaining to the preparation of packages for shipmen .6.4 Delivery of Completed Packages to Carriers The inspector verified that the licensee's procedures included the required NRC and DOT regulations. A review of selected records and shipping papers for i radioactive waste shipments indicated that the licensee had prepared appropriate manifests and shipping papers in accordance with approved .

procedures. The shipping papers included the necessary information to comply ;

with regulatory requirements. The licensee only used exclusive use carriers for all radioactive waste shipments and assured that the following items were in accordance with NRC and DOT regulations and station procedures: radiation levels were within required limits, transport vehicles were properly ,

placarded, 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 transi The inspector was not able to observe licensee activities involving radioactive materials shipments, because no shipments were performed during the period of the inspection. This was d':e to the fact that the burial site was closed to the licensee for shipment of radwaste, and the licensee did not have any laundry shipments scheduled for the wee .6.5 Records, Reports, and Notifications The inspector reviewed selected records of radioactive waste shipments made by the licensee during 1994. The licensee's shipments were adequately documented r

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to meet NRC and D0T regulations. The licensee maintained records of all radioactive waste and materials shipments as required. The records included all shipping documentation, radiation surveys, and required notification data. t 1.7 Conclusions Very good audits and surveillances were performed by qualified individual The audits and surveillances identified pertinent findings and corrective actions for the findings were timely. There had been no major changes in facilities, equipment, programs, or procedures; only minor organizational and procedural changes were mad (. .

-8-The Radwaste Department had an adequate, well-qualified staff to meet staffing requirements. The licensee had maintained an excellent training program for radwaste personne Good implementing procedures had been established for the radioactive waste management progra Radioactive waste was shipped offsite for burial in the first half of 1994 to reduce the onsite inventor The low-level radioactive waste disposal program was conducted in accordance with the requirements of 10 CFR 20.2006, 61.55, and 61.5 The licensee maintained good implementing procedures that addressed waste classification and characterization, selection of packages, preparation of packages, and delivery of the completed packages to the carrier. Individuals responsible for transportation of radioactive waste were knowledgeable of the regulatory requirements and burial site license condition !

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f 0 ATTACHMENT I PERSONS CONTACTED Licensee Personnel

• D. F. Boan, Quality Assurance Specialist

• J. Houghtaling, Technical Services Manager

• D. A. Landeche, Lead Supervisor, Radiation Protection Support

• S. Landry, Radwaste Foreman

• R. LeBlanc, Acting Licensing Manager

• A. S. Lockhart, Quality Assurance Manager

• R. Prados, Senior Engineer, Licensing L. Simon, Senior Engineer, Radiation Protection

• T. A. Thiesse, Modifications Manager, Plant Modification and Control 1.2 NRC Personnel E. J. Ford, Senior Resident Inspector

• Denotes personnel that attended the exit meeting. In addition to the personnel listed, the inspector contacted other personnel during this inspection perio EXIT MEETING An exit meeting was conducted on July 22, 199 During this meeting, the inspector reviewed the scope and findings of the report. The Technical Services Manager committed to revise a training procedure as discussed in Section 1.3 of this repor The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector.