IR 05000397/1991007
| ML17286A731 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/12/1991 |
| From: | Chaney H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286A729 | List: |
| References | |
| 50-397-91-07, 50-397-91-7, NUDOCS 9104300277 | |
| Download: ML17286A731 (25) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION REGION V.
Report No.
50-397/91-07 License No.
NPF-21 Licensee:
Washington Public Power Supply System (Supply System)
P.
0.
Box 968 3000 George Washington Way Richland, WA 99352 Facility Name:
Washington Nuclear Project. No.
2 (WNP-2)
Inspection at:
WNP-2 site, Benton County, Washington Inspection Conducted:
February 25 through March 1, 1991 Inspected by:
D; C aney, Sen)or Radiation Specialist Date igned Approved by:
P.
as, Chief Reactor Radiological Protec
'
Branch Da e Signed Summary:
Ins ection Durin Februar 25 throu h March 1 1991 Re ort No. 50-397/91-07 Areas Ins ected:
Routine unannounced inspection of the licensee's radiation protection (RP) program including:
Occupational radiation exposure, solid radioactive waste (radwaste)
and transportation, exposure control planning and preparations for refueling outage R-6, and follow-up on previous inspection findings.
Inspection procedures 83750, 86750, 83729, 92700, and 90713 were Used.
Results:
Two apparent violations of NRC requirements involving the failure to classify properly a radioactive waste (radwaste)
shipment, see paragraph 4.d(l), and the failure to register as a user of an NRC certified shipping package/cask, see paragraph 4.d(2) were identified during this inspection.
Also, one licensee identified deviation concerning the failure to implement fully commitments made in response to NRC Inspection and Enforcement Bulletin 79-19 regarding initial and periodic retraining, of personnel..involved. in radwaste and radioactive material (RAM) transportation activities was discussed, see paragraph 4.b.
The licensee's implementation of their responsibilities in the area of shipping and disposal of radioactive material is generally adequate, however, it appears the recent increased management oversight in this area has not been fully effective as evidenced by the apparent violations found during this inspection.
Licensee actions to reduce plant personnel radiation exposure were noted.
9104300277 9i04i5 PDR ADOCK 05000397
~,
DETAILS 1.
Persons Contacted Licensee
+J.
Baker, Plant Manager
- R. Graybeal, Health Physics/Chemistry Manager
"J. Arbuckle, Compliance Engineer
"J.
Harmon, Maintenance Manager
"D. Wer lau, Training Manager Health Physics/Chemistry
"G. Sorensen, Regulatory Programs
"R. James, ALARA Coordinator Others
"D ~ Williams, Bonneville Power Administration, Engineer (") Denote personnel that were at the exit meeting held on March 1, 1991.
(+) Denotes that the Plant Manager was not in attendance at the formal exit meeting but was briefed on March 1, 1991, about the inspection findings by the inspector.
Additional licensee personnel attended the exit meeting and other licensee personnel were contacted during the inspection and not reflected in the above listing.
2.
Occu ational Ex osure 83750 a.
Plannin and Pre aration The inspector examined and observed the licensee's planning and preparations for the accomplishment of two radiological work operations involving varying degrees of radiological hazards'he licensee's planning and execution showed a high degree of preplanning and coordination.
RP controls were comprehensive and effectively implemented.
ALARA.concerns were well thought out and prework briefings of workers were considered exceptional in content and presentation.
(1)
The first job reviewed involved the receipt of new reactor fuel and involved a minimum of radiological hazards.
Personnel exhibited good knowledge of the procedural requirements and radiological hazards of the operations.
The prehandling radiological surveys were effectively obtained and analyzed.
The inspector reviewed the following procedures (PPM-Plant Procedures Manual) and Radiation Work Permit (RWP) during this work operation:
PPM 6.2. 1, R-S, "Receipt of New Fuel and Shipping Truck To Bay Activities" PPM 6. 2. 2, R-9,
"New Fuel Handling, Railroad Bay to Refueling Floor Activities"
PPM 6.2.3, R-9,
"New Fuel Handling on the Refueling Floor" PPM 6.2.4, R-9,
"New Fuel Inspection" PPM 6.2.5, R-8, "Fuel Channel Preparation, Inspection, and Installation on New Fuel" RWP No. 2-91-00065,
"Receipt and Inspection of New Fuel" The inspector determined that PPMs and the RWP provided radiological workers with sufficient radiological control instructions.
Noteworthy was the fact, that the ALARA staff prework review identified that 58 percent of the exposure received during the last inspection of new fuel was incurred by the personnel working on the refueling bridge.
The fuel handling mast and spent fuel pool water skimmer were identified as the primary dose contributors.
During this job, specific work controls to reduce personnel exposures were implemented (prework briefings and identification of low dose areas on the refueling bridge).
An adequate level of performance was exhibited by the licensee during this job.
The second job reviewed involved the entry into the upper mezzanine area of the Traversing Incore Probe room to try and stop leakage at a flanged orifice (Reactor Water Clean Up (RWCU) system orifice No.
RWCU-FE-040).
The leak involved reactor coolant flashing to steam.
The plan was to stop the leakage by having a contracted service company (vendor) inject
'
special thermal setting sealant into a specially designed collar placed between both flanges of the orifice.
Vendor calculated injection pressures (licensee reviewed) would theoretically prevent entry of the sealing compound into the RWCU system via the leak path.
'I The working conditions involved both radiological and industrial hazards; i.e., radiation hotspots of approximately 15.0 R per hour, high levels of loose surface contamination (60,000 disintegration per minute to 12. 0 millirad per hour),
and a cramped working space that exposed workers to live steam, unlagged hot pipes, and low overhead obstacles.
The workers were also subjected to poking/puncturing type protrusions when navigating their way to the leaking orifice.
Airborne radioactivity was less than one MPC-hour.
Still, the potential existed for higher levels of airborne radioactivity due to the steam leak and high surface contamination levels.
The licensee and vendor expected that two or more entries would be necessary to to measure the flanges, install the collar, and inject the sealing compound.
The inspector'xamined the RWP issued for the job (2-91-00067),
attended the Health Physics (HP) group conducted prework briefing (attendees included vendor, maintenance, quality assurance (gA), engineering, and ALARA personnel),
and entered the RWCU room with the work crew.
The prework briefing was very good and instructional.
The inspector observed procurement of pocket dosimeters (self reading and alarming),
setting of alarm, values, placement of.dosimeters, selection of respiratory protection (including the verification of each worker's qualifications and the qualitative fit test of
'espirators by the workers prior to entering the work area).
Other than some'spot melting of the plastic protective clothing on hot pipes the job wen't according to plan.
This melting did not result in any personnel, injury or contamination.
The work practices of workers and HP technicians (HPTs) were excellent.
During the entry the special collar was found to require additional machining (a few thousandths)
for it to fit between the flanges properly.
The job was successfully completed a day later.
The inspector considered licensee preparations and execution of this job to be very good.
HP ALARA s'taff use of still pictures and the video taping'f a previous entry into the room was an excellent aid in developing personnel dose reduction techniques and briefing of workers on potential problems.
The inspector did advise plant management that housekeeping in the room was less than adequate and would cause unnecessary generation of.'
radioactive material and wastes if not rectified.
The workers'ttempts to minimize the introduction of additional clean materials into the work area were satisfactory.
b.
Maintainin Occu ational Ex osures ALARA Pro ram and Or anization The inspector examined the licensee organization and implementation of their ALARA program to determine agreement with NRC Regulatory Guides (RGs) 8.8 and 8. 10.
The inspector reviewed staffing of the HP Planning Group (ALARA staff/program implementation).
The licensee has filled all positions in the HP planning group and is developing ALARA strategies.
Three licensee HPTs, an ALARA Coordinator, and a supervisor make up the HP ALARA staff.
All possess extensive experience in radiological controls involving commercial nuclear power plants.
The ALARA staff exhibited excellent enthusiasm about implementing a quality ALARA program and reducing personnel exposure expenditures.
The inspector examined the licensee's philosophy regarding the MNP-2 ALARA program.
This philosophy is described in several higher level licensee administrative documents.
Corporate Policy and Procedures Manual, Volume 3, Section 3. 1.2,
"As Low As Is Reasonably Achievable (ALARA)"
Nuclear Operating Standard 38, "Radiation Protection" PPM 1. 11.2,
"ALARA Program Description" The ALARA program is describe in PPM l. 11.2, and implementation is via PPM 11.2.1.2 and PPM 1.1.6, referenced below.
Responsibilities and authorities are adequately assigned in the above noted documents.
Concepts are consistent with industry
guidance in this area.
Recent licensee audits have identified that current HP position titles are out of date in several procedures such as PPM 1. 11.2
-, the position of HP Planning Supervisor is not reflected and the procedure shows that the HP/Chemist Support Supervisor has direct oversight involving the HP ALARA'ortion of the program.
The following sampling of plant administrative and RP/ALARA procedures-were examined:
PPM l. 1. 6, R-5,
"ALARA Committees" PPM 1.2.4, R-12, "Plant Procedure Review, Approval and Distribution" PPM l. 3. 7, R-ll, "Maintenance Work Request" PPM 1.4. 1, R-ll, "Plant Modif'ications" Radiological Programs Instruction Manual procedure RPI-.
2.7, R-2,
"ALARA Engineering Analysis" PPM l. 11.2, R-4,
"ALARA Program Description"
"
PPM l. 11. 8, R-2, "Radiation Work Permit" PPM 11. 2. 1.2, R-5,
"As Low As Reasonably Achievable Program Implementation" PPM 11.2.2. 1, R-2, "Post Activity Evaluation" The licensee had established three separate but integrated ALARA committees at WNP-2 (Senior Site ALARA, Plant ALARA, and ALARA Working Group).
Each committee's charter and
, responsibilities are setforth in PPM 1.1.6.
The Senior Site ALARA Committee has just begun to hold meetings at a monthly frequency.
Plant management'nvolvement is visible in all aspects of the ALARA program.,
. The review of selected plant. modifications (see NRC Inspection Report No. 50-397/91-03),
a post job completion ALARA review
'(Sludge Separator Tank sparger nozzle cleaning - Maintenance Work Request No.
AR-,.2503),
and discussions with HP ALARA staff members, maintenance scheduling/planning personnel, and systems engineers showed 'that the applicable ALARA aspects in the above noted procedures are being effectively factored into daily work activities and long'range planning.
(2)
ALARA Goals and Ob ectives The inspector held discussions with HP Planning Group personnel and reviewed current initiatives to reduce the plant collective'adiation exposure expenditure (person-rems).
ALARA goal development uses several trendable time increments such as per job,'er outage, per day, or per month.
Total facility performance is based, on a fiscal-year period starting on July 1st of each year.
The licensee had initially established a plant person-rem expenditure goal of 480 for the 1990-1991 fiscal year.
In February Of this year the HP ALARA staff recommended that this goal be reduced to 465 person-rem.
The licensee had allotted approximately 300 person-rem for the upcoming R-6 outag (3)
ALARA Reviews The ALARA'taffhas'recently increased their efforts on performance of pre and post job reviews (PPM 11.2.2.3).
The ALARA staff's performance on the prejob review of new fuel inspection and the post job review of the Sludge Separation Tank sparger nozzle cleaning (RWP 2-91-00042
& 00046)
wer e both excellent and showed by detailed prework surveys, exposure trending, and manhour tracking that significant exposure reductions and general work performance can be greatly enhanced by such reviews.
(4)
ALARA Results Based on preliminary industry exposure expenditure data for the year 1990 the licensee will again exceed the national average for like facilities by a significant amount.
The 1989 national average for plants similar to WNP-2 was 439 person-rems.
As in the past this average is expected to be lower for 1990.
However, the inspector notes that the licensee is placing greater emphasis on plant wide ALARA involvement, pre and post job exposure reduction evaluations, factoring in to future work operations their own and industry lessons learned information, and aggressively implementing exposure reduction concepts to reverse this trend.
3.
Occu ational Ex osure Durin Extended Outa es 83729 a ~
Plannin and Pre aration The licensee's radiological control planning and preparations for the upcoming (April 1991) refueling outage (R-6) were examined for agreement with prevailing industry practices and licensee ALARA goals for this year.
The inspector held discussions with key licensee personnel responsible for the R-6 outage management and planning, including the HP Department ALARA staff.
At the time of this inspection the licensee had identified that the HP organization would provide RP services via two twelve hour shifts and use first line supervisors as HP shift leaders, with approximately 10 senior HP technicians providing coordination of radiological work in 5 specific plant work areas (Reactor Building, Reactor Building refueling area, drywell, Turbine Building, and balance of plant).
The licensee had already started bringing in HP coordinators for familiarization with their intended duties, and to provide assistance in the development of area specific RWPs.
Approximately 240 job specific RWPs (mostly small valve work) will be generated for this outage.
This outage will not involve any unique work activities not'reviously experience by the licensee.
Discussions with the plant outage manager did not identify any major work activities that were not known to the ALARA planning superviso I hl t'
b.
Trainin and uglification of New Personnel The licensee, will utilize contract HP technicians (C-HPTs) to supplement their permanent HP staff.
The inspector reviewed the licensee selection criteria for C-HPTs to the requirements contained in TS 6.3. 1.
PPM 1.8.4, "gualification of Plant and Support Contractor Personnel,"
provides instructions on certification of evaluations.
The licensee's selection process for C-HPTs involves th'e evaluation of a prospective employee's previous experience at WNP-2 (first quasi qualifying criteria), verification of time in-grade/performance level and experience of each applicant.
Following selection each C-HPT must pass (if not previously accomplished at WNP-2)
a comprehensive written RP practical factors examination and then attend site specific procedures training.
Contract HPTs are eval'uated by staff HPTs before being allowed independent control over work operations.
The licensee had initiated actions to bring several C-HPTs onsite early so that a few plant HPTs can get started on outage preparations involving work scheduling, RP equipment, expendable supplies, and work area walkdowns.
Detailed training and testing schedules for C-HPTs (HP screening examination, respiratory protection equipment testing, etc.,)
have been developed by the Nuclear Training Department.
An excellent program is being implemented by the licensee for selection of contract HPTs and compliance with TS requirements.
No violations or deviations were identified in this area 'of the inspection.
4.
Solid Radioactive Waste Mana ement and Trans ortation of Radioactive Materials 86750 The licensee's solid radwaste management and radioactive material (RAM)
transportation programs were examined to determine compliance with the requirements of WNP-2 Technical Specifications (TS) 3. 11.3, 6.8. l.h,
.6.9.1.11, and 6.13,
CFR Parts 20.311, 61.55, 61.56, and 71.5, and Department of Transportation (DOT) regulations contained in 49 CFR Parts 170 through 189; and agreement with the guidance provided in NRC Inspection and Enforcement Bulletin (IEB) No. 79-19,
"Packaging of Low-Level Radioactive Waste for Transport and Burial," and various NRC Inspection and Enforcement Information Notices (IEIN) related to radwaste and RAM transportation activities.
a.
Audits and A
raisals The inspector examined audits and appraisals conducted in this area since the last inspection of this area (NRC Inspection Report No.
50-397/90-22).
The Supply System Executive Board of Directors (the Board)
had an assessment made of the WNP-2 radioactive waste management program activities.
An external consulting firm conducted the assessment during the period October 22 through November, 16, 1990.
The final report of the assessment findings was forwarded to the Supply System Managing Director on January 29, 1991.
The individual performing the assessment appeared to possess
exceptional qualifications and experience in the area of auditing radwaste management and transportation activities.
The final report identified approximat'ely 90 adverse findings concerning the overall program with most of the emphasis on radwaste management.
Findings involved activities associated with budget appropriations,-
organization, staffing, training, liquid and solid waste processing, procedure adherence, radwaste minimization, solid radwaste compaction, waste classification and characterization activities, radwaste shipment manifest computer program, and mixed waste management.
At the time of this inspection, plant management was compiling a response to the assessment findings.
Discussions with plant management indicated that the response will include a commitment to implement a comprehensive corrective actions program concerning the findings.
Trainin and uglification of Personnel The inspector examined current training programs (classroom and on the job training - OJT) for personnel involved in the processing, packaging, and transporting or offering for transport radwaste and RAM.
Discussions were held with lead instructors and the training discipline manager.
Selected annual retraining sessions for HPTs, and plant technical staff and managers were attended.
The following licensee training lesson plans and training documentation were reviewed.
O 1990 and 1991 HP/radwaste annual retraining attendance rosters.
WNP-2 Radwaste Laborer Training Course Catalog, R-O, dated February 1, 1991 WNP-2 Decontamination Laborer Training Course Catalog, R-O, dated February 1, 1991 Radwaste Laborer Training Program gualification Signoff Sheets Decon Laborer Training Program gualification Signoff Sheets gualification and OJT Matrixes for Radwaste Workers and Waste Sorters The licensee's current training program for radwaste workers and vendor processing equipment operators appears to satisfy the conditions of IEB 79-19 except for establishment of initial and annual retraining program for HP supervisors associated with these activities.
The consultant's assessment identified that the licensee had not fully implemented the conditions of IEB 79-19 concerning initial training and retraining of personnel associated with the processing, packaging and transportation of radwaste.
The assessment noted that the person currently occupying the position of Radwaste Supervisor had never attended WNP-2 nor recent industry provided training on radwaste and transportation regulations.
The contract employee performing verification signoffs on some RAM transportation forms
I
had never'articipated in WNP-2 radwaste/transportation training.
It was not clear in the assessment whether equivalent training was provided by the contractee's company.
The licensee had committed in a Supply System letter, Serial No..
G02-79-147, dated August 28, 1979, to meeting the recommendations contained in the IEB when their plant(s)
reached the operating stage.
The failure to implement fully the conditions contained in IEB 79-19 constitutes a deviation to a commitment made to the NRC.
Because identification of this deviation was the result of a licensee sponsored assessme'nt and the licensee has provided the inspector with suitable assurance that all deficiencies will be corrected and current radwaste supervisor and staff training will put the licensee in agreement with'heir 1979 commitment to implement IEB 79-19, a
written response to this deviation will not be necessary.
A
'follow-up on implementation of corrective actions will be made during future inspections-of this area (397/91-07-01).
The inspector verified the licensee's possession of current radioactive waste burial permits and regulations for transporting waste and RAM.
The licensee's radwaste processing and RAM transporting procedures are comprehensive, and are currently undergoing major revision due to recent NRC and gA audit findings.
All procedures will be "walked-down" to verify their correctness and viability. prior to reissue.
The licensee has issued procurement authority to purchase a new state of the art computerized radwaste management system to replace the current one.
Unlike the previous system this computerized program will be, validated by both the vendor and an independent licensee work group.
Training of the radwaste staff and interested support groups (gA, gC, and HP supervisors, HPTs, etc.,)
and validation wi 11 be completed prior to any future shipments of radwaste.
Im lementation of the Solid Radwaste Pro ram As previously noted in this report the consultant's,assessment identified serious deficiencies with the licensee's program in this area.
Deficiencies in this area included waste stream characterization practices and potential problems.with the computer program used to classify wastes for shipment to burial sites.
The assessor stated that "Should the Radwaste Organization and Radioactive Waste Management Program be allowed to continue in its present direction, it is likely that serious infractions in the classification and/or shipment of radioactive waste could occur,-
Staffing of the HP group's solid radwaste program is one supervisor, three radwaste laborers, a Radwaste Coordinator (HPT), and a vendor supplied 1iquid processing equipment operator.
The assessment judged this area to be under staffed and the staff not properly trained.
The licensee's program is described and implemented by
several procedures.
The inspector performed a cursory examination of the following radwaste procedures:
PPM 1. 12. 1, R"4, "Radioactive Waste Management Program" PPM 1. 12.2, R-4, "Radioactive Waste Process Control Program" PPM 1. 12.3, R-12, "Contract Vendor Waste Processing" PPM 11.2.23.2, R-7, "Radioyctive Waste Classification" PPM 11.2.23.5, R-3, "Testing 8 Adsorption/Solidification of Radioactive Waste Liquids 4 Sludges" PPM 11.2.23. 13, R-l, "Operation of Radwaste'Compactor" PPM 11.2.23. 14, R-3, "Sampling of Radioactive Waste Streams" PPM 11.2.23. 16, R-l, "Dry Active Waste Sorting" PPM 11.2.23. 17, R-O, "Fl'oor Drain Flushing" PPM 11.2.23. 19; R-O, "Operation of Pacific Nuclear Resin Drying System" PPM 11.2.23.27, R-O, "Operation of Mixed Waste Storage Area" The licensee procedural requirements contained in PPM l. 12. 2 and 1. 12.3 only allow the use of NRC approved vendor supplied Process Control Programs and waste solidification/dewatering topical reports.
Licensee procedures routinely incorporate industry and NRC lessons learned information and technical position standards.
The licensee's semiannual effluent reports for 1990 accurately reflect solid radwaste generation, processing activities, changes to the licensee's own Process Control Program, and radwaste shipment activities as required by TS 6,9. 1. 11.
Tours of the licensee's solid radwaste processing facilities determined that they were as stated in Section 11 of the Final Safety Analysis Report for WNP-2.
The inspector observed dry radwaste (plastics, wipes, papers, damaged protective clothing, etc.,) sorting and disposal preparations..
Potentially contaminated waste disposal appears to conform to the guidance contained in NRC IEIN No. 85-92,
"Surveys of Waste Before Disposal From Nuclear Reactor Facilities."
The inspector noted to the licensee that the installed spent resin (radioactive) transfer piping that has terminations both within the Radwaste Building and at a location outside of it (see WNP-2 P&ID DWG M-536 sheet 2) was not clearly labeled as to its radiological hazard/function at the piping terminations outside of the Radwaste Building.
Independent radiation exposure rate measurements at the terminations did not identify radiation levels above background.
The inspector related to the Radwaste Supervisor that current HPT retraining was reviewing lessons learned from an event involving workers at another nuclear power plant receiving unnecessary radiation exposure when some spent resins were inadvertently allowed to enter a piping system not expected to have resin in it.
The Radwaste Supervisor visited the area identified by the inspector.
The supervisor stated that actions would be taken to identify clearly the purpose of the piping and effect administrative controls (if not already inplace) to ensure proper valve positions were maintained.
The proper identification of these piping terminations
will be considered an inspector follow-up item for future
.inspections of this"area (397/91-07-02).
d.
Shi in of Low-Level Wastes For Dis osal, and Trans ortation The licensee's transportation activities supervisor has been in place approximately six months (see NRC Inspection Report Nos.
50-397/90-22 and 90-29)
and possesses dated experience and training as noted by the consultant's assessment.
The licensee has implemented corrective actions to remedy this deficiency.
The inspector reviewed the 1'icensee's Semiannual Effluent Reports for the periods January 1, 1990 - June 30, 1990 and July 1, 1990-December 31, 1990.
The licensee's reports comply with the requi r ements of TS 6. 9. 1. 11.
The inspector examined selected licensee shipments of radwaste and RAM, during the period of August 1990 to the date of this inspection, for compliance with NRC/DOT regulations.
Two apparent violations of NRC/DOT requirements were identified.
CFR Part 61 requires, in part, that radioactive wastes destined for near surface disposal shall be classified and characterized according to the requirements of 10 CFR Parts 61. 55 and 61. 56.
The above requirements are implemented by WNP-2 TS 3. 11.3, which requi:res, in part, that "Radioactive wastes shall be SOLIDIFIED ot'ewatered in accordance with the PROCESS CONTROL PROGRAM to meet shipping and transportation requirements during transit,'nd disposal site requirements when received at the disposal site."
Furthermore,
CFR Part 20.311(d)(l), requires, in part, that "Any generating licensee who transfers radioactive. waste to a land disposal facility.;.
(1) Prepare all wastes so that the waste is classified according to (10 CFR Part) 61.55 and meets the waste characteristics requirements in (10 CFR Part) 61.56 of this chapter;"
On January 30, 1991, the licensee shipped a container'of dewatered radioactive resins to the commercial low-level radioactive waste disposal site near the licensee s facility.
Inspections conducted on the 'same day at the burial site, by the State of Washington inspectors, disclosed that the waste was misclassified as meeting the stabilization criteria for Class B wastes (10 CFR Part 61.55 and 61.56).
This shipment of dewatered resins was contained in a steel liner that did not meet the stability'requirements of 10 CFR Part 61.56 or the licensee s burial site permit.
The licensee determined that a
lack of understanding of the computerized radwaste management program and an inadequate review of the waste classification calculations required by 10 CFR Part 61. 56(a)(4) were responsible for the violation.
The specific problem involved the sum of fractions calculations and two radioisotopes (cesium 137 and strontium 90) that exceeded the 10 CFR Part 61.55, Table 2 limits.
The shipment was returned to WNP-2.
The
II I
br I
I
licensee upon finding out about the shipment rejection suspended further resin processing and shipping of any radwaste until the problem was thoroughly evaluated and corrected.
This action complied with the "Action Statement" of TS 3. 11.3.
The licensee informed the NRC regional office on January'30, 1991 of the pr'oblem.
On February 4, 1991, the State of Washington informed the licensee that WNP.-2's authorization to use the commercial low-level radioactive waste disposal site was suspended for an indefinite period.
This suspension would remain in effect until the Supply System requested reinstatement and the, State of Washington determined that the licensee had brought their activities into full compliance with all applicable state and federal regulations.
The licensee's failure to comply with TS'.11.3 and.the resultant misclassification of radwaste is considered a
violation of NRC requirements setforth in 10 CFR Part 20.311.
However, since the licensee's response to the State of Washington appears to be comprehensive and likely to prevent a
recurrence of this problem no response to this violation will be required.
The licensee indicated to the inspector that corrective actions would most likely include, but are not limited to:
(1) revising waste classification procedures;.(2)
revising shipment procedures to provide for. specific review criteria for all shipping paperwork; (3) subjecting all shipments to a review by two separate Supply System personnel; (4) procurement of an alternative waste classification and management computer program; (5) having the Radwaste Supervisor and the dewatering process equipment operator attend Supply System training on NRC and DOT regulations; (6) complete and redundant. verification of the new computer codes used, results for test shipments, and the first group of shipments of radwaste following their exit from the 'TS 3.11.3 Action Statement; (7) the training program for radwaste workers will be revised to add the Radwaste Supervisor and other applicable radwaste employees to the training matrix, and that the Radwaste Supervisor and other key personnel will be required to attend annual offsite refresher training on industry standards'nd NRC/OOT regulations.
The NRC will follow-up on the licensee's corrective actions to this violation during future inspections of this area (397/91-07-03).
In order for an entity to use an NRC approved package for the transportation of RAM a general license must be obtained in accordance with NRC regulations.
CFR Part 71.0.(a),
"Purpose and Scope," states, in part, that "This part establishes:
(1) requirements for packaging, preparation for shipment, and transportation of licensed material; and (2)
procedures and standards for NRC approval of packaging and shipping procedures for...
a quantity of other licensed material in excess of Type A quantity.
Further,
CFR Part 71.4, "Definitions," state, in part, that A2 means the maximum
J
I i
f E
activity of radioactive material,... permitted in a Type A
package."
CFR Part 71. 12(c)(3),
"General License:
NRC.
approved package,"
requires, in part, "This general license applies only to a licensee who:...
Submits in writing to the Director, Office of Nuclear Safety and Safeguards, U.S. Nuclear Regulatory Commission,... prior to the licensee's first use of the package, the licensee's name and license number and the
package identification number specified in the package approval."
The licensee routinely uses four different NRC-Certified Packages, both Type A and B.
Licensee procedures provide detailed instructions on the inspection, preparation and loading of the package for shipment of RAM (normally the vendor's instructions are directly incorporated into licensee specific procedures).
The following procedures and packages are used by the licensee.
I PPM 11.2.23.20, R-l, "Use of NUPAC Services Transport Cask Model 14/210L or 14/210H."
NRC Certificate of Certification (CofC) No.
9176.
PPM 11.2.23.21, R-l, "Use of NUPAC Services Transportation Cask Model 10/142."
NRC CofC No.
9208.
PPM 11.2.23.22, R-1,
"Use of LN Technologies Corporation Transport Cask Model LN 14-170."
NRC CofC No.
9151.
PPM 11.2.23.24, R-l, "Use of US Ecology Transport Cask Model 14D-2.0.",
NRC CofC No.
9079.
The licensee's and NRC documents (NUREG-0383, Volume 1, Revision 3, dated October 1990)
showed the licensee was accepted as an authorized user for all packages except NRC CofC No.
9208, Model No.: 10-142.
The licensee indicated that they had been a registered user of LN Technologies'ackage Model No. 142, NRC CofC No.
9073, prior to the use of the NUPAC package Model No.10-142, NRC CofC No.
9208.
The licensee considered them to be the same package and had not registered as a user of the NUPAC 10-142 package prior to its use for shipping radwaste.
There are differences in the packages especially in the area of the impact-limiter for Type B
qualification.
The licensee s two 1990 semiannual reports'show that the licensee used the NUPAC 10-142 package for the shipment of radwaste in greater than Type A quantities on at least 6 other instances during 1990.
The inspector examined one shipment record (90-52-02)
documenting the use of the NUPAC 10-142 package (serial No.
97382) in the year preceding this inspection.
The State of Washington issued a Notice of Violation concerning this shipment when the contents within the package were determined to have an external dose rate of 15. 1 R/hour at one meter when the manifest showed that the contents had a reading of less than or equal to.002 R/hour.
This is a significant radiological concern to the burial site personnel due to the possibility of incurring unnecessary personnel exposures during
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unloading of the cask.
Since the contents were accurately described on the shipping papers (49 CFR Part 173.200)
as to the quantity of radioactivity within the package and the package was properly label - no regulatory issues were apparently violated.
The licensee determined that 'this incident was the result of a misuse of.the radwaste and transportation computerized manifest generating program and fai lure to perform an adequate review of the shipping papers prior to releasing the shipment.
The inspector further determined that licensee procedure PPM ll;2.23.20 indicates in the title th'at the applicable package is NRC CofC No.
9151 when it is actually 9176.
The licensee's failure to register as a user of an NRC certified radioactive material shipping package when shipping greater than Type A quantities of radioactive materials is considered an apparent violation of 10 CFR Part 71. 12 requirements (397/91-07-04).
All other aspects of the licensee's RAM/radwaste transportation activities appear to comply with NRC/DOT regulations.
Even though the licensee's management of radwaste and RAM transportation activities is less than the quality expected of an NRC licensee; MNP-2 is for the most part conducting operations in compliance with NRC/DOT regulations and the current problems are not suggesting a programmatic breakdown.
However, the licensee's performance in this area requires the immediate attention of Supply System management to preclude further deterioration of the program and to ensure future compliance with NRC/DOT regulations.
The licensee's response to the consultant's assessment and development of corrective actions where warranted will be considered an inspector follow-up item for future inspections (397/91-07-05).
The inspector met with,licensee representatives identified in paragraph
of the report on January 18, 1991.
The inspector discussed the scope and findings of the inspection.
The inspector informed the Plant Manager of the inspection findings and the NRC's concerns regarding problems identified in the area of radwaste and.RAM transportation activities.
The inspector's concerns were acknowledged and the Plant Manager stated that resources were being directed towards evaluating and developing responses to the consultant's assessment and findings discussed by the inspecto e t
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