IR 05000445/1990028

Insp Repts 50-445/90-28 & 50-446/90-28 on 900716-20.No Violations Noted.Major Areas Inspected:Licensee Radioactive Matl Transportation & Solid Radwaste Programs

ML20059F321
Person / Time
Site:	Comanche Peak
Issue date:	08/29/1990
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059F305	List: IR 05000445/1990028 ML20059F302
References
50-445-90-28, 50-446-90-28, NUDOCS 9009110179
Download: ML20059F321 (10)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report:

50-445/90-28 Operating License: NPF-87 50-446/90-28 Construction Permit: CPPR-12i Dockets:- 50-445 t

50-446

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Licensee:

TV Electric

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Skyway Tower 400 North Olive Street, L.B. 81

Dallas, Texas 75201-

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t Facility Name: Comanche Peak Steam Electric Station (CPSES)

Intpection At: CPSES site, Glen Rose, Texas inspection Conducted: July 16-20,1990 f

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Inspector:

u R. E. Baer, Senior 'Re4ct(rJ Health physicist Ddte Facilities Radiolopi/a1 Notection Section

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Approved:

A 3. Murray, Chie Facb ities Radiological Ddte

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Protection Se on Inspection Summary

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Inspection Conducted July 16-20,1990 (Report 50-445/90-28: 50-446/90-28)

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~ Areas Inspected:

Routine, unannounced inspection of the licensee's radioactiveL material transportation and solid radioactive. waste' programs.

Results: Within the areas inspected, no violations or deviatis.s were identified. The organization and management controls appearea adequate and

were responsive to NRC initiatives.

Personnel had been trained and were being.

retrained as necessary.

Past audits had been compliance based using auditors'

who had been trained but lacked field experience. The transportation program had not been used for the shipment of radioactive waste. Three open items were identified. The licensee was not a registered user for NRC certified casks, the provisions for emergency response information had not been completed,.and

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the FSAR did not accurately depict the plant solid waste system. The solid waste system had not routinely operated and temporary systems were still being installed.

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DETAILS

1.

Persons Contacted

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TU Electric

• A. Scott, Vice President, Nuclear Operations

'O. Bhatty, Issue Interface ~ Coordinator, Quality Assurance (QA)

• J. B. Burnett, Staff Health Physicist i

P. A. Chadwick, Training Spscialist

• J. D. Edwards, Jr., Health Physics (HP) Supervisor, Corporate HP

• R. E. Fishencord, Radiation Protection (RP) Supervisor

• T. A. Hope, Site Licensing

• D. C. Kay, Senior Engineer, Corporate HP

• B. Lantz, QA Auditor

• R. J. Prince, RP Manager

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B. R. Shell cove, Mechanical Quality Control (QC) Supervisor

• J. F. Stree.ir, Executive Assistant

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• C.

L. Terry, Director, QA.

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S. K. Wakefield, Training Specialist i

Others

• W. D. Johnson, NRC Senior Resident Inspector

• Denotes those present during the exit interview on July 20, 1990.

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t The inspector also intersdewed se,veral other licensee personnel during the

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course of the inspection.

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2.

Open Items Identified During This Inspection An open item is a matter that requires further reviaw and evaluation by

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the inspector. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector.

The following open items were identified.

Open Item Tit,le See Paragraph

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445/9028-01 Registered User for NRC Certified 6b 446/9028-01 Casks 445/9028-02 Emergency Response Information for 6.d i

446/9028-02 Radioactive Material /Radwaste Shipments 445/9028-03 FSAR Section 11.4 Update

446/9028-03 l

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3.

Organization and Management Controls

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The inspector reviewed the licensee's organization and management control programs to determine compliance with the Technical Specifications (TS)

and commitments in the Final Safety Analysis Report (FSAR).

l The organizational structure for the radioactive material / waste program was found to be in agreement with commitments contained in Section 13.1 of

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the FSAR. The licensee had issued a policy statement, nuclear engineerin i

and operating (NED) Policy No. 23, " Radioactive Waste Management Policy,"g Revision 2, February 2, 1990, which addressed the company's policy for the long-term management of both high-level and low-level radioactive waste

material.

Procedure NE0-2.07, " Radioactive Waste Management Progrv."

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Revision 1. February 2,1990, assigns the administrative and technical responsibilities for the radioactive waste management program including

solid, liquid, and gaseous effluents.

The radiation protection manager has designated a radioactive material'

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control supervisor, five technicians, and a secretary to support the program. The station administration manual procedures in the 600 and 700 series provides the overall guida...:: Mr the orogram and additional radiation protection instructions (RPIs) in the 200 series implement the program. The specific procedures reviewed are listed in the Attachment to this report.

l The inspector noted that the licensee was in the fi al stage of developing f

l some of the checklists such as Form RPI 203-1, "Prit e Notification l

Checklist," to implement some procedures.

During the review of selected I

completed checklists, the inspector also noted that Form RPI 210-1, " Cask Shipment Checklist," required the RP section to assure that the cask lid

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bolts were properly torqued. The inspector discussed the advantage to involve QC in this evolution. As a result of these discussions, the_

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licensee decided to revise Form RPI-210-1 to include a QC checkoff and a

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designated space to document the measuring and test equipment used, serial number, calibration date, calibration due date, and torque valves. This

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I appeared to be an isolated occurrence where HP personnel performed this

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work function without QC involvement.

No violations or deviations were identified.

4.

Training and Qualifications l

The inspector reviewed the licensee's training program for personnel involved in the transportation of radioactive materials and solid

radioactive waste managemeat to determine agrecment with commitments contained in the FSAR and in response to NRC Inspection and Enforcement

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Bulletin (IEB)79-19.

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The inspector reviewed the training provided and qualificstions of RP, QA and QC personnel assigned to radioactive materials transportation

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activities.

All individuals had received vendor-supplied training which

had been designed to meet the commitments in response to IEB 79-19. The

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site-specific training program for QC inspectors was in the development i

stage. The inspector also reviewed the performance-based audit training program described in Lesson Plan QA21.LAT.AU3, March 28, 1990, being

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. presented to QA personnel.

The inspector determined that personnel responsible for the transportation of radioactive materials and solid radwaste program met the qualifications specified in the FSAR and American National Standards Institute (ANSI) N18.1-1971.

No violations or deviations were identified.

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Audits

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The inspector reviewed the licensee's QA audit and surveillance program for solid radioactive waste management and transportation of radioactive materials to determine compliance with the commitments in the FSAR, and

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the requirements of 49 CFR Parts 171-178 and 10 CFR Parts 20, 61, and 71.

The inspector reviewed the QA manaal, audit procedures, audit checklist, I

audits, and surveillances conducted during the period January 1989 to

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July 1990.

The inspector also reviewed audit findings, corrective action

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tracking and responses to findings, and auditors' qualifications. The

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inspector noted that orevious audits and surveillances were compliance based. The licensee had limited activities in progress in tM area of solid radioactive waste management and transportatie,i activities during

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the period in review. The next audit is not sched. sled until 1991 which the licensee stated would be a performance-based audit.

Audit QAA-89-24A i

included, in addition to the radioactive waste con'.rol program, the

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radiation protection program and Offsite Dose Calctlation Manual.

Deficiencies that were noted had been resolved in a timely manner.

i The inspector noted that QA personnel did not possess technical expertise

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in the area of radioactive materials transportation activities.

l No violations or deviations were identified.

6, Radioactive Materials Transportation Program

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The inspector reviewed the licensee's radioactive materials transportation program for compliance with the requirements of 10 CFR Parts 20, 61, and 71, and 49 CFR Parts 171 through 178; agreement with commitments to NRC IEB 79-19 and Chapter 11 of the FSAR; and the recommendations of NP.C Regulatory Guides 7.1 through 7.10.

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a.

QA program l

The inspector determined that the licensee had submitted a QA program

for NRC approval to comply with 10 CFR Part 71, Subpart H.

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licensee's QA program had been approved and' documented on NRC Form 311. " Quality Assurance Program Approval," Approval No. 71-0504,

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indicating an expiration date of February 28, 1994.

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Procurement and Selection of Packages The inspector reviewed the licensee's program for the procurement of

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Department of Transportation (DOT) and NRC certified packages. The inspector determined that the licensee had not used an NRC or DOT

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certified package. The licensee had made a selection of various size

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packages that they may use and had obtained from the packages owner

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the manufacturer's design, use, maintenance, testing, and NRC certificate of compliance for those packages.

However, the licensee had not filed the necessary documentation to become a registered user for any packages.

The licensee plans to become a registered user.

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The status of the licensee's registration program for NRC and DOT certified packages is considered an op_en item pending further review

by the inspector. (445/9028-01; 446/9028-01).

The inspector noted that the licensee had procured for the shipment of low-specific activity waste steel boxes as-strong tight containers and steel drums manufactured in-accordance with DOT Specification 17H. The manufacturers of these boxes and drums are on the licensee's " Approved Vendor List" which indicates that the manufacturers' QA testing program is acceptable, c.

Preparation of Packages for Shipment The inspector verified that the licensee had established procedures

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L and checklists for the preparation of radioactive materials l

shipments.

These procedures included requirements for a visual t

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inspection of the package prior to loading the package, instructions

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for closing and sealing the package, marking requirements of the

package's weight and curie content, labeling requirements for the appropriate type of package, and determining the radiation and contamination limits of the package. The licensee had established QC hold or check points during the preparation of the packages.

Discussions with licensee personnel indicated that individuals involved in transportation of radioactive materials activities possessed a working knowledge of the related procedures sufficient to ensure that the aspects of DOT and NRC regulations pertaining to the preparation of packages for shipment were being met.

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d.

Delivery of Completed Packages to Carriers The inspector compared the licensee's procedures with the DOT and NRC requirements to determine if requirements concerning delivery of

completed packages to carriers were included. The inspector verified

that licensee procedures had been revised to include the reportable quantity information described in Appendix to 49 CFR Part 172.101 on

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the shipping manifest as required by 49 CFR Parts 172.203 and

172.324.

The inspector noted that the emergency response information required by 49 CFR Part 172, Subpart G, had not been incorporated into the licensee's procedures. An effective date of April 2, 1990,

had been established in Volume 54, Federal Register 27138. The

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licensee had the necessary information to incorporate these

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requirements, but were under the impression the effective date was

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September 1990. The licensee had not offered for transport any radioactive materials which would have required this emergency response information.

The licensee plans to make the necessary

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revision to upgrade their computer generated shipping records to l

iaclude this information. The status of emergency response

information is considered an open item pending further review by the inspector (445/9028-02; 446/902F02).

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The inspector's review of licensee's records and shipping. paper i

documentation indicated that the licensee had prepared appropriate shipping papers in accordance with approved procedures and that the shipping papers included the necessary information to comply with current regulatory requirements.

The licensee had established procedures that used checklists to ensure that the radiation levels are within the required limits. The licensee's procedures address the taking of photographs of the loaded transport including the vehicle driver just prior to shipment. The inspector determined from

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a review of photographs and records of previous radioactive material i

shipments that the transport vehicle was properly placarded, removable surface. contamination on packages were within regulatory

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limits, and blocks and/or braces were properly placed to prevent

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damage or shift of the load under conditions normally encountered in transit.

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Receipt of Packages f

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The inspector reviewed the licensee's program for receipt of packages

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containing radioactive material to determine compliance with 10 CFR Part 20.205.

The licensee's activities for receipt of radioactive materials were covered by Procedure RPI-202, " Receipt of Radioactive Material,"

Revision 5, September 30, 1988.

The inspector reviewed this i

procedure for consistency with regulatory requirements and determined

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that it covered all aspects of the work being performed.

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Records, Reports, and Notifications The inspector reviewed the records of eight radioactive material

shipments in 1989 and three made in 1990 by the licensee. These

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shipments had been adequately documented to meet the NRC and DOT

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requirements.

These shipments involved radioactive sources but did not include radioactive waste material.

No violations or deviations were identified.

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Solid Radioactive Waste Management l

The inspector reviewed the licensee's solid-radioactive waste program to I

determine agreement with the commitments in Chapter 11 of the FSAR.

The licensee had not made any changes to the solid radioactive waste

system regarding the piping, location, and size of equipment installed.

The licensee had contracted for a vendor to supply a mobile cement solidification and resin dewatering system with an approved topical report / process control program for the solidification of waste effluents.

The inspector noted that the licensee was preparing to install a resin

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sample system downstream of the present installed system, between the discharge valve and the portable solidification unit.

The present installed system does not provide a representative sample of the entire waste stream being discharged and sample volume would not meet the ALARA

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criteria for a highly radioactive waste stream.

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The licensee had placed a portable demineralizer into the area originally designated for the storage of drummed radioactive waste.

This leaves very little space within the fuel building for the storage of drummed waste, i

The inspector discussed with licensee representatives that Chapter 11.4 of the FSAR should be reviewed, specifically Figure 1.2-38 which depicts area 250 as a drum storage area and presently contains the portable demineralizer. This is considered an open item pending the licensee's

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evaluation of Chapter 11.4 of the FSAR (445/9028-03; 446/9028-03).

10 CFR Part 50.71(e)(3)(1) allows a licenc e 24 month: to update the FSAR after i

issuance of the operating license The licensee received their operating license in February 1990.

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The inspector also discussed with licensee representatives that the portable solidification system should be placed on some type of preventive maintenance schedule to reduce the potential for a leaking or ruptured l.

hose. The licensee stated they would review this matter and may also l

place a spill kit to contain a spill should one occur.

l The inspector noted that clean trash generated inside the radiologically

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contrriled area (RCA) is surveyed and monitored four times prior to release for disposal.

Clean trash generated outside the RCA within the

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protected area was r-et n:nitored at all.

The licensee agreed to periodically inenitor *.he trash prior to its release to ensure no radioactive material is released.

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Exit Interview The inspector met with the senior resident inspector and the licensee representatives denoted in paragraph I at the conclusion of the inspection on July. 20, 1990, and summarized the scope and findings as presented in

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this report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during this inspection.

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ATTACHMENT

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_%cuments Reviewed Title Revision Date 1.

Procedures STA-302 Station Records

10/11/89 STA-650 General Health Physics Plan

10/20/89 STA-652 Radioactive Material Control

03/30/90 STA-653 Contamination Control Program

04/06/90 TNL-404 Changes to CPSES Operating

01/17/90 Licens. Prerequisite Documents TRA-205 P.adwaste Operator Training

01/03/90 TRA-301 Radiation Protection Training

12/15/89

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RPI-201 Shipment of Excepted Radioactive

11/01/89

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Material RPI-202 Receipt of Radioactive Material

09/30/88 RPI-203 Shipment of Radioactive Materials

11/01/89 RPI-204 Dry Active Waste Processing

04/26/90 RPI-205 Wet Waste Processing

09/13/89 RPI-206 Liquid Process Filter Control

09/14/89 RPI-207 New Fuel Survey

11/01/89 RPI-208 Operation of the Model 2407 Stock

11/01/89 Compactor RPI-209 Radioactive Material Classification 1 11/01/89 RPI-210 Radioactive Waste Cask Handling

11/01/89 RPI-212 Rao'nactive Source Control

01/17/90

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RPI-213 Survey at.1 Release of Material

11/01/89

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Title Revision Date RPI-216 Waste Stream Sampling and Data

01/22/90 Base Maintenance RPI-217 Operation of the Automated Tool

03/19/90 Frisker (AFT-1)

RPI-218 Operation of t 6 Automated Bag

03/19/90 Monitor (ABM-1)

RPI-219 Operation of.the Universal

03/30/90 Conveyor Monitor (UCM-2)

RPI-223 Calibration of the Automated Tool

05/11/90 Frisker RPI-224 Calibration of the Bag Monitor

06/18/90 NEO 2.07 Radioactive Waste Management

02/02/90 Program 2.

Audits'and Suve111ances-QAA-89-24A, " Radiation Protection Program / Radioactive Waste Control Program /0ffsite Dose Calculation Manual," September 28 through October 6, 1989 QAS-90-487, " Radiation Protection Self Assessment Program," May 7-22, 1990

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