IR 05000382/1998001
| ML20199H761 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/29/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199H750 | List: |
| References | |
| 50-382-98-01, 50-382-98-1, NUDOCS 9802050116 | |
| Download: ML20199H761 (13) | |
Text
_ -
- -.. = - -..
..
. _ - -
-
. - -
-. - - _. - - -..
.. - -.. -..,
. - _.
-
'
.
,
e
.
,
j IRC10DMRE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
.
i
Docket No.:
50 382 License No.:
NPF 38 floport No.:
50-382/98-01
,
Licensee:
Entergy Operations, Inc.
f Facility:
Wateriord Steam Electric Station, Unit 3 Location:
Hwy 18 i
Killona, Louisiana -
Dates:
January 1215,1998 Inspector:
J. Blair Nicholas, Ph.D., Senior Radiation Specialist -
Plant Support Branch Approved By:
Slaine Murray, Chief, Plant Support Branch Division of Reactor Safety
Attachment:
SupplementalInformation
>
i
i
1
'
9902050116
PDR ADOCK 0 382
,
G PM
_
-
. _,._
..-. -.
. -.,
..
.,.
.-
--
.
-2-EXECUTIVE SUMMARY Waterford Steam Electric Station, Unit 3 NRC Inspection Report 50-382/g8-01 This annomted, routine inspection reviewed the implementation of the solid radioactive waste managernent and the radios;tive waste / materials transportation programs. Training, quality
!
assurance overright, and procedural guidance were also reviewed.
I kiA1AGWd
A very good solid radioactive waste management program was implemented. The
-
amount of dry active waste generated had been reduced (Section R1.1).
A very good transportation program for radioactive waste / materials was maintained.
- Documentation and packages were properly prepared for shipment (Section R1.2).
l Good facilities were maintained for the processing, storage and management of solid
TPlloaClive Wastes and transportation activities,. An effective radiractive waste inventory 8, stem was maintained (Section R2).
l Procedures established to implement the solid radioactive waste management and
transportation programs provided proper guidance for the handling, processing, and shipping of radioactive waste / materials (Section R3).
Parsonnelinvolved in the transfer, packaging, and transport of radioactive materials and
wastes were properly trained and qualified (Section RS).
A proper organization and staff were maintained which effectively implemented the solid
radioactive waste management and transpertation programs (Section R6).
An effective audit program was maintained. Good management oversight was
maintained for the solid radioactive waste management and transportation programs.
Condition reports related to radioactive waste activities were closed in a timely manner.
There was appropriate evaluation of the contractors' performance (Section R7).
___
_
___ _____ - __ _ _ - -_-_____ _
.
..
3-Engott Delalls Summary of P:anL&iatus Waterford Unit 3, operated at full power during this inspection. No events occurred during this inspection that adversely affected the inspection resuris.
,
IV. Plant SMDR0d R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Solid Radioactive Waste Management i
a.
{0soection Scong.(&QZ.EQ)
The inspector interviewed the radwaste specialist and reviewed the following solid l
radioactive waste management program activities:
Waste stream sampling results and waste characterization documentation
Scaling factors
Solid radioactive waste classification j
'
Quantities of radioactive waste shipped for disposal
+
Waste minimization program
+
Annual radioactive waste effluent release reports
b.
Qbitiyahons and Findinas The inspector verified that waste t' ream samples were taken annually and analyzed to meet 10 CFR Part 61 requirements for waste classification and characterization. Five waste streams were identified that consisted of dry active waste, resins, and filters. The waste stream samples were analyzed by a contractor laboratory.
The inspector verified that a proper radwaste computer code was used to classify the radioactive waste. Scaling facto a determined from waste stream sample analyses were updated annually in the radwaste computer code data base. No problems related to waste stream sampling or waste classification were identified. The inspector noted that the radwaste computer code was updated with the most current revisions of the vendor software, after verification and acceptance of the revisions by the licensee.
The inspector noted that the licensee had made good progress to reduce the amount of dry active waste geenerated. Radworker awareness was enhanced to minimize radioactive waste when performing their assigned tasks. Licensee data trends showed these radwaste minimization efforts were effective.
The volume of radwaste generated prior to segregation, processing, or volume reduction was tracked by the licensee. Overall, the licensee's data showed a decline in dry actne waste generated. The increases in dry active waste volume generated during 1994,
- - -..
--
.
-
.- -._ -
_
--
-
-
_ -
-. -.
-
.-
..
t
- 4*
t 1995, and 1997 were the result of extended outages. The licesee met the waste generation goals established for 1996 and 1997.
Solid Waste Reduction Results (Cubic Feet of DAW)
1992 18,648 1993 2,497 1994 9,630 1995
.
3,749 1996 1,521
-
1997 7,821 The annual radioactive effluent release reports contained the required solid radioactive waste data, Dry active waste was shipped to an off-site vendor for volume reduction and subsequent burial A summary of the volume and activity of solid radioactive waste including,*esins, irradiated components, and dry active waste shipped for disposal during the lasi six years is tabulated below The increase in volume and activity for 1994, 1995, and 1997 were the result of outages. The significant increase in activity for 1995 resulted from the shipment of incore instrumentation for disposal.
'
Number Of Volume Activity Year Shipments (m )
(Cl)
1992
242.17 3,926 1993
251.03 103 1994
501.97 1,377 1993
285.84 12,931 1996
137.91 151.5 1997
310.90 237.8
..
c.
' Conclusions A very good solid radioactive waste management program was implemented. Waste.
.
' stream sampling and analyses met regulatory requirements. Solid radioactive waste was properly classified and characterized for shipment and disposal. The generation of dry active wastes had been reduced.
m
.
.
RI.2 Transoortation of Radioastive Waste and Radioactive Materials a.
Insoection Scope (86750)
The inspector interviewed the radwaste specialist and reviewed the following:
Shipping documentation from selected shipments
Certificates of compliance for NRC-certified shipping casks
Copies of current Department of Transportation and NRC regulations
Copies of current licenses for recipients of radioactive wastes / materials
Use of a vendor supplied computer program to generate shipping papers
Packaging and shipping papers
Marking and labeling of packages for shipment
Vehicle placarding and driver instructions
Emergency response information
Radiation surveys of packages and vehicles
Use of system intemational(SI) units
b.
Observations and Findings Selacted shipping records for shipments between January 1996 and December 1997 showed that the licensee had made shipments of both radioactive waste and radioactive materials. Shipments requiring Type B packaging were made by the licensee. The inspector noted that the licensee was a registered user for the NRC-certified shipping casks used. No problems were observed concerning the radioactive shipment records reviewed. No shipments were msde during the week of the inspection; therefore, no observations of actual shipment preparation were possible.
Certificates of Compliance for routinely used shipping casks were verified. State shipping permits were reviewed. The inspector reviewed selected shipment consignees and verified that the licensee maintained current copies of the consignees radioactive material licenses on file. The inspector noted no problems in the documentation reviewed.
A proper vendor supplied radwaste computer code was used to determine proper radioactive material transportation categories, shipping packages, labeling, and shipping paper information.
Shipping papers for radioactive materials shipments contained the information required by 49 CFR Part 172, Subpart C. In addition to this information, radioactive waste shipment documentation included manifests that conformed to the requirements of 10 CFR Part 20, Appendix F and 49 CFR 173.433. Shipping documents included radioactive activity measurements recorded in international system units as well as customary units. The inspector verified that proper emergency telephone numbers were included with the shipping papers.
\\
_ _ _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ _
_ - _ _
-
.
.
Radiation survey records indicated that radiation and contamination levels of shipments were within regulatory limits.
c.
Conclusions A very good ti
.crtation program for radioactive materials and radioactive waste was maintained. Du smentation and packages were property prepared for shipment.
R2-Status of Facilities and Equipment a.
Inspection Scope (86750)
l The inspector toured the radweste processing facilit;es and the low-level radioactive l
waste / material storage building and observed tne following:
l
'
Container storage and labeling
+
Container accountability
b.
Findings and Observations inspection of the radioactive waste processing and storage facilities revealed that good radweste facilities were maintained. The radweste stornoe areas were properly posted and controlled. Radweste containers were properly
I and marked.
Shipments of radioactive wastes were made in a timely manner to maintain the radioactive waste inventory at a minimum. The licensee kept excellent records of radweste container accountability. The inspector verified that selected radweste containers were stored as documented in the radioactive waste inventory records.
c.
Conclusions Good facilities were maintained for the processing, storage, and management of solid radioactive wastes and transportation activities. An effective radioactive waste inventory system was maintained.
R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Transoortation Procedures a.
Insoection Scone (86750)
The inspector reviewed the procedures used to implement the solid radioactive waste management and transportation programs.
_ _
..
-
-
.
,.... _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
_-_-
.
.
b.
Observations and Findings The inspector determined that appropriate guidance was provided in the radwaste procedures for radioactive waste stream sampling, vendor laboratory analysis, and updating the computer code data with new waste stream sample analysis results and I
scaling factors. Effective checklists were utilized to provided guidance for the preparation of radioactive waste and radioactive materials shipments.
c.
Conclusions Procedures established to implement the solid radioactive waste management and transportation progran s provided good guidance for the handling, procescing, and shipping of radioactive waste / materials.
R4 Staff Knowledge and Performance The inspector interviewed the radwaste specialist, who is member of the radiation protection department and the qualified shipper responsible for the implementation of the solid radioactive waste management program and all radioactive waste / materials transportation activities. The radwaste specialist was very experienced and had an
,
excellent working knowledge of the transportation regulations.
R5 Staff Training and Qualification in Radiological Protection and Chemistry RS.1 Trainina and Qualification of Radwaste Personnel a.
Insoection Scooe f 86750)
The inspector reviewed the training of personnel who were responsible for the preparation and packaging of radioactive waste and radioactive materials for shipment.
The inspector reviewed the following:
Training materials related to 49 CFR Parts 171 179 and 10 CFR Part 71
Training and qualification records
-
Retraining requirements
b.
Observations and Findings The inspector verified that training records documented that the radwaste specialist (qualified shipper) and all radwaste technicians involved in radwaste processing and transportation activities were properly trained and qualified.
An effective biennial retraining program was conducted in accordance with commitments made in response to NRC Sulletin 7919," Packaging cf Low Level Radioactive Waste for Transport and Burial."
.
__-_--
..
.
c.
Conclusions Personnel involved in the transfer, packaging, and transport of radioactive materials and radioactive wastes were properly trained and qualified.
R6 Radiological Protection and Chemistry Organization and Administration The organization and staffing for the implementation of the solid radioac'ive waste management and transportation programs were reviewed, A radwaste specialist and 13 radwaste technicians effectively implemented the radioactive waste management and transportation programs. The radwaste staff had experienced no change or reduction in staff since the previous inspection of this area conducted in July 1996.
-R7 Quality Assurance in Radiological Protection and Chemistry Activities R7,1 Solid Radioactive W3ste and Transoortation Proaram Assessments a,
Inlagetion Scone (86750)
Biennial audits ind a peer evah * 'lon were reviewed to evaluate the licensee's effectiveness at identifying and cu.recting problems, The review also included the following:
Qualifications and resumes of auditors and a technical specialist
Condition reports of radioactive waste and transportation activities
b.
Observations and Findinas Quality assurance audit SA 97-024.1, 'Radwaste Processing / Packaging and Shipping,"
was conducted February 21 through March 25,1997. An audit of the solid radioactive waste area is conducted every 24 months in accordance with Technical Specification requirements. The audit team included an off site technical specialist.. The inspector determined that the audit was comprehensive in its review of solid radioactive waste management and transportation activities.
A radwaste peer evaluation was conducted in April 1997. The peer evaluation was based on observations of activities in progress or existing plant conditions. The evaluation report was effective in providing feedback to radwaste management on program effectiveness.
No quality assurance surveillances were performed of the solid radioactive waste manaCement and radioactive waste / materials transportation progrems. The performance of quality assurance surveillances of radioactive waste / materials shipments was discussed with the licensee as a program enhancement to ensure that the required shipping documentation was prepared for all shipments of radioactive material or waste.
The licensee stated that they would evaluate the use of quality assurance surveillances
.
_
_
_
__
,
.g.
during the preparation of radioactive waste / materials shipments and take appropriate I
action as a result of their evaluation.
Audit findings were tracked as part of the condition reporting system. The inspector notJd that the radiation protection organization responded properly to the findings. Other selected condition reports involving radioactive waste activities were reviewed. No adverse trends were noted. Appropriate corrective actions were taken and timely closure was noted.
The auditors' qualifications were reviewed, including the resume of the technical specialist used to assist in performing the latest audit. The qualifications and experience of the auditors and technical specialist were appropriate. The inspector determined that the experience of the lead auditor for radwaste activities was very good. However, the inspector noted that the lead auditor had not received formal training on the revised transportation regulations. However, there is no regulatory requirement to provide this specific training to auditors. During the exit meeting, the licensee stated that the lead auditor was scheduled to take refresher training on the currently revised radwaste packaging transport and disposal regulations in March 1998.
c.
Conclusions A good quality assurance program was maintained. Through the use of a comprehensive audit and a recent peer evaluation, the licensee maintained a good management oversight program for the solid radioactive waste management and transportation programs. A technical specialist knowledgeable in radioactive waste management and transportation requirements was a member of the audit team.
Condition reports related to radioactive waste activities wers closed in a timely manner.
R7.2 Quality Assurance Program for Contractors a.
Insoection3ecoe (86750)
The quality assurance vendor audit program regarding contractors performing surveillance activities involving the solid radioactive waste management program was reviewed.
b.
Observations and Findings Contractors were used to perform processing of solid radioactive waste and volume reduction, radwaste transportation and cask rental, radwaste disposal services, and radiochemistry analyses of radwaste samples for 10 CFR Part 61 waste classification i
and characterization rsquirements.
The licensee used nuclear procurement issues committee audits of the contractors to evaluate the performance of their respective radwaste activities. The audits were comprehensive and satisfactory to evaluate each of the contractor's abilities to perform their respective radwaste activites.
l l
l
_ _ _ _ _ _ _ - _ -
d C
10-c.
Conclusion There was appropriati evaluation of the contractors' performance.
R8 Miscellaneous Rwdlological Protection and Chemistry issues I
R8.1 (Closed) LER 97-008: Incorrect Quantity of Tri-Sodium Phosoha'.e Used For ECCS Subsystem DH Determination On March 17,1997, the licensee identified that Technical Specification surveillance
'
requirement 4.5.2.d.4 was performed on April 19,1988, with a quantity of tri-sodium phosphate in excess of the required amount. Specifically, the surveillance test was performed with 4.032 grams of tri-sodium phosphate instead of 4 i 0.01 grams. This was 0.022 grams greater than allowed by the Technical Specification. This was identified by the licensee as a violation of Technical Specification 4.5.2.d.4.
l The licensee performed a review of all prior Technical Specification 4.5.2.d.4 l
surveillance test records. Data from all similar surveillances performed since 1988 l
indicated that the correct amtont of tri sodium phosphate was used and that surveillance results met Technical Specificati>n requirements. The licensee also evaluated the effects of using a tri sodium pho sphate sample 0.022 grams larger than allowed by the Technical Specification. Theoretical calculations using 4.032 grams and 4.00 grams of tri' sodium phosphate produced a pH difference of 0.01 pH units when dissolved in the same boric acid concentration that was used for the performance of the surveillance test.
The calculational results indicated that the 1988 surveillance test would have satisfied the pH requirements of a7.0 pH units if the correct sample size of tri sodium phosphate had been used.
The licensee implemented corrective Lctions to review and stress with all members of the chemistry department the need for procedure compliance and proper post job document review. The surveillance test procedure was also revised. The inspector verified that the licensee's corrective actions were completed.
.
This non repetitive, licensee-identified and corrected violation is being treated as a
!
Non-Cited Violation, consistent with Section Vil.B.1 of the NRC Enforcement Policy.
(50-382/9801-01)
V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee's management at an exit meeting on January 15,1998. The licensee acknowicdged the findings presented. No proprietary information was identifie *
...
ATTACHMENT
,
l
. SUPPLEMENTAL INFORMATICN I
PJRTIAL LIST OF PERSONS CONTACTED
- Licensee C. Dugger, Vice Prosident, Operations R. Allen, Manager, Operational Experience Engineering M. Brandon, Supervisor, Licensing.
A. Cilluffa, Technical Training Supervisor, Training G. Dolese, Technical Specialist, Chemistry E. Ewing, Director, Nuclear Safety and Regulatory Affairs l
T. Gaudet, Manager, Licens;ng I,
C. Hayes, Technical Coordinator, Nuclear Safety and Regulatory Affairs G. Hood, Supervisor, Chemistry P. Kelly, Field Support Supervisor, Radiation Protection D. Landeche, Superintendent, Radiation Protection S, Landry, Specialist, Radiation Protection (qualified shipper)
T. Leonard, General Manager, Plant Operations T. Lett, Lead Supervisor, Radiation Protection D. Newman, Quality Specialist, Quality Assurance J. Noehl, Technical Training, Training G. Pierce, Director, Quality Assurance R. Prados, Senior Lead Engineer, Licensing D. Rieder, Quality Assurance Engineer, Quality Assurance C. Thomas, Supervisor, Licensing M. VanDerhorst, TecMical Training, Training NBC J. Keeton, Resident inspector INSPECTION PROCEDURE USED 86750 Solid Waste Management and Transportation of Radioactive Waste ITEMS OPENED AND CLOSED Ooened 382/9801 01 NCV Incorrect Quantity of Tri-sodium Phosphate Used for Performance of Surveillance Test
.
.
.
.
..
_-
_ _ - _ _ _ _. __-___ ____ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ - -
.
-2-Closed 97 008 LER Incorrect Quan'ity of Tri-sodium Phosphate Used For ECCS
{
Subsystem pH Determination
'
-382/9801-01 NCV Incorrect Quantity of Tri-sodium Phosphate Used for Performance of Surveillance Test LIST OF DOCUMENTS REVIEWED ORGANIZATION CHART Radiation Protection Department TRAINING AND QUALIFICATION DOCUMENTATION NTC-237 Radwaste Services Training, Revision 13 NTC-238 Radwaste Services Continuing Training, Revision 8 LP-RW-HZREQ Hazardous Materials Requalification Training, Revision 0 i
l Training records for the radwaste specialist and radwaste technicians l
(
QUALITY ASSURANCE AUDITS AND PEER EVALUATION Audit SA-95-024,1, "Radwaste Processing / Packaging and Shipping," conducted February 7 through March 6,1995 Audit SA-97-024.1, "Radwaste Processing / Packaging and Shipping," conducted February 21 through March 25,1997
"Radwaste Peer Evaluation" conducted April 28 through May 2,1997 VENDOR AUDITS NUPIC Joint Quality Assurance Audit of Chem-Nuclear Systems, Inc., conducted May 20-24, 1996 NUPIC Joint Quality Assurance Audit of Babcock & Wilcox Nuclear Environmental Services, Inc., conducted January 25-27,1995 -
NUPIC Joint Quality Assurance Audit of Scientific Ecology Group, Inc., conducted April 15-19, 1996
.
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
__
-
.
ic+f-3-PROCEDURES UMT-007-006 Housekeeping, Revision 7
- UNT-007-026 Hazardous Materials Management Program, Revision 7 RW-001210 Process Control Program, Revision 8
RW-002-110 Waste Sample Collection, Revision 6
~ RW-002-200 Collection and Packaging Radioactive Solid Waste (DAW) for Disposal, Revision 1 RW-002-300 Receipt, Storage and Loading of Shipping Containers, Revision 11 RW-002 310 Storage of Loaded Shipping Containers, Revision 5 RW-002-320 Radioactive Waste Control, Revision 9 RW-002-501 Radioactive Material / Waste Shipments, Revision 7 REPORTS
. Annual Radioactive Effluent Release Reports _1995 and 1996 OTHER Selected radweste condition reports T
..
!