IR 05000445/1999005

Insp Repts 50-445/99-05 & 50-446/99-05 on 990222-26.One Violation Noted.Major Areas Inspected:Implementation of Solid Radwaste Mgt & Radioactive Matls Transportation Programs

ML20204E997
Person / Time
Site:	Comanche Peak
Issue date:	03/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20204E989	List: IR 05000445/1999005 ML20204E984
References
50-445-99-05, 50-445-99-5, 50-446-99-05, 50-446-99-5, NUDOCS 9903250198
Download: ML20204E997 (10)

Text

.- -

ENCLOSURE U.S. NUCLEAR REGULATCRY COMMISSION

REGION IV

Docket Nos.: 50-445 l 50-446 i License Nos.: NPF-87 NPF-89 .

Report No.: 50-445/99-05 )

50-446/93-05 Licensee: TU Electric Facility: Comanche Poak Steam Electric Station, Units 1 and 2 !

Location: FM-56 Glen Rose, Texas Dates: February 22-26,1999 Inspector (s): Michael C. Hay, Radiation Specialist Plant Support Branch Approved by: Gail Good, Chief Plant Support Branch Division of Reactor Safety Attachment: SupplementalInformation i

9903250198 990319 PDR ADOCK 05000445 G PDR

-2-EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report No. 50-445/99-05; 50-446/99-05 This announced, routine inspection reviewed the implementation of the solid radioactive waste management and the radioactive materials transportation programs.

Plant Support

. The solid radioactive waste management program was implemented well. Waste stream sampling and analysis met regulatory requirements. Solid radioactive waste was properly classified and characterized for shipment and disposal. Solid radioactive waste temporarily stored on site was located in properly posted and controlled areas (Section R1.1).

I

• A good transportation program for radioactive materials and radioactive waste was maintained. The process of removing a high integrity container from a shielded vault I and preparing it for shipment in a shipping cask was conducted very proficiently keeping radiation exposures as low as reasonably achievable (ALARA). Shipping papers contained the required information, and packages were properly surveyed and labeled (Section R1.2).

• Due to a tracking error, the licensee fa!!ed to request renewal of its quality assurance i program within 30 days of expiration. The NRC expedited its renewal so the licensee i could continue radioactive shipping activitics (Section R1.2).

• Personnel responsible for implementing the transportation program for radioactive waste and materials were knowledgeable, experienced, and had an excellent working knowledge of the transportation regulations (Section R4).

• Radiation protection personnel involved in the transfer, packaging, and shipping of radioactive materials and radioactive waste were properly trained and qualified. A violation of 49 CFR 172.704 was identified involving the failure of two radwaste quality control inspectors to receive function specific training every three years. This violation was placed in the licensee's corrective action program as SMART Form 1999-00037 This Severity Level IV Violation is being treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy (Section RS.1).

• Comprehensive audits performed by qualified personnel effectively evaluated the solid radioactive waste and transportation of radioactive material / waste programs (Sectivn R7.1).

• The corrective action process was effectively used to identify problems, perform evaluations and assessments, and implement timely corrective actions (Section R7.2).

• Housekeeping throughout the radiological controlled areas was very goo . l

.

-3-Report Details IV. Plant 1.uoport R1 Radiological Protection and Chemistry Controls R Solid Waste Manaaement Inspection Scope (86750)

The inspector interviewed selected personnel responsible for implementing the

- licensee's radioactive materials control program, toured plant facilities, and reviewed records associated with the storage and characterization of radioactive waste stream Observations and Findinas During tours of the radiological controlled areas, the inspector confirmed that radioactive waste was stored in accordance to commitments in Section 11.4.2.7 of the licensee's Final Safety Analysis Report. Areas used for storage of waste were propcrly controlled and posted. Tha inspector noted that housekeeping throughout the radiological controlled aross was very good. No problems were identified with the licensee's storage of radioactive materials and wast Inventory of radioactive material and waste was properly performed every six months as required by procedure. The inspector used the last waste inventory performed on February 23,1999, and verified that all waste was properly accounted for in the vault storage ycrd used for temporary storage of low level radioactive wast The inspector verified that waste stream samples were routinely collected and analyzed to meet 10 CFR Part 61 requirements for waste classification and characterizatio Annual waste stream samples were collected and analyzed by a contractor laborator Scaling factors for isotopes in each waste stream were determined and updated in the radwaste computer code. The inspector reviewed selected waste classification documentation and identified no problem Conclusions The solid radioactive waste management program was implemented well. Waste stream sampling and analysis met regulatory requirements. Solid radioactive waste was properly classified and characterized.for shipment and disposal. Solid radioactive waste temporarily stored on site was located in properly posted and controlled area Housekeeping throughout the radiological controlled areas was very goo R Transportation of Radioactive s Material Inspection Scope (86750)

following:The inspector observed shipping activiti

• es and reviewed selected examples of the

Shipping paper documentationRenewal approval of quality a Vehicle placardingPackage marking and labeling Observations and Findings Shippino Activities The inspector observed the licensee p reactor coolant system filter mediahigh repare for hiintegrity container contai i radiation exposure rates up to 23 arem n ng s pment. The high integrity container had radiation levels, performance of an acciden per hour on contac of radiatiactivity The pre-job was briefing f tho ssion of personnelassignments, expected or the on surveys, and emergency actions in the event The licensee prepared the high integrit placing it into a shipping y containercas PriorintoWaichouse for shipment he ractivityC consi T

shielded vault, the inspector egrity container from made a tour f th a shielded

.

vault and to the warehouse was not posted emoving o as the high integrity container e ware e from th integrity contaradiation protection

, a radiationtechnician area. house who p noted that an entry way and its corrective The licensee action roperly program.posted the initiatedentry way, prior to th hTh e igh SMART Formr 1999 000379o e posted as a

-

to place this issue in The procoss of removing the high inte i was conducted very proficiently keeping r di preparing the high integrity grcontainer ty fo container andng placing cask it in the s 1 workers involved. Continuous evolution health physi r shipment resulted in 10 millirem total d

{ to ensure. Radiation surveys were appropriately ose to all conducted i

!

49 CFR 173.441 and 173 443

.

.

Plexternal using calibrated equipment e radiation, and c

\ package, and the shippi vehicle acards andwas labels were properly placed on ths we properly placarde e Documentation i

Se!ected solid radioactive waste and deficienciesidentifie o Certificates material shipping recordsf C were reviewed with shipping permits and fil ompliancecurrent copies for routinely used ofnoshipping s

thwerecask verified. T e consignee's radioactive es on materiallicen

-- _-

.

'

i-5-Shipping pt.vrs for radioactive materials shipments contained the information required by 49 CFR 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 173.43 Renewal of auality assurance oroaram aooroval l

On February 22,1999, while reviewing the licensee's quality assurance program approval dated February 2,1994, the inspector noted that the expiration date was February 28,1999 (6 days later). Quality assurance program approval is required for the licensee to perform activities associated with the procurement, maintenance, repair, and use of transportation packages associated with the shipment of radioactive !

materials.10 CFR 71.38 states, in part, that licensees who submit for renewal not less

{

than 30 days before the expiration of an existing quality assurance program approval will continue to have approval until final action on the application for renewal has been taken by the Commission. As of February 22,1999, the licensee had not submitted an application for renewal of the quality assurance program. The licensee stated that it i

was late requesting the quality assurance program approval because the wrong date '

was entered in the record keeping database used to track reports or issues that are coming due, in order to prevent the licensee's quality assurance program approval from expiring on February 28,1999, the NRC expedited a renewal approval on February 26, 1999. The licensee placed this issue into its corrective action program using SMART j Form 1999-000363 to evaluate if other deficiencies exist in its tracking syste c. Conclusions A good transportation program for radioactive materials and radioactive waste was maintained. The process of removing a high integrity container from a shielded vault and preparing it for shipment in a shipping cask was conducted very profic*ently keeping radiation exposures ALARA. Shipping papers contained ths rec uired information and packages were properly surveyed and labeled. Due to a tracking system error, the licensee failed to request renewal of its quality assurance program within 30 days of expiration. The NRC expedited its renewal so the licensee could continue radioactive shipping activitie R3 Radiological Protection and Chemistry Procedures and Documentstion a. Inspection Scope (86750)

The inspector reviewed the procedures used to implement the solid radioactive waste management and transportation program b. Observations and Findinas

! Proper guidance was provided in the procedures for radioactive waste stream sampling, l

vendor laboratory analysis, updating the computer code data with new waste stream sample analysis results, and scaling factor generation. The licensee's transportation

!

i

.

.

shipments. proceduresn to were-6- fou d Conclusions containa the ppropriate l Programmatic evelof detailfor the pre controls parationo f R4 radioactive waste / mat Staff Knowledge erials wereemented,ng, properlyimplandprocedures processing, and The inspectorintervieand Performanceshipment of radioactive waste o and materialtransportatiwedmembers knowledgeableconducting on the transport f the ra transportation re,gul activitie R5 experienced, ation n and c hadaationPersonnelreation program volvedin for radioa ti pro R Staff Training and Q excellent working knowlve waste andma Trainin ere edge of the P_!trgpoop_ejand e

o Qualification g calProtection f Radiualificationin Ins ation Protection and Chemistry

\ ection Sco e 86750 and Qualit for the preparationTheinspectorreview Control Radwaste d shipmen andpackaging of radioe the training and qualifi Observations active waste o andradioacation records and Findin s nnelresponsible ctive theinspector radioactive o

noted thDuring a review materials fforsel was then material verifiedat/wa as radiation ste for hipm byani ures protectionected operatingproce controlinspector to ensure regulatory staff requindependent ent. Thepackagingand memberprepared mentation, thand shippin radiation p implement theTheinspector rements verified shipping o documentatioepackage f rotection were staff membe n properly trained solid radioactive and q pr c wastethat radiation satisfie rand a quality prote ti quality activities controlinspector ualifie s However,ocessing and tranon staff members who were training every threewho were responsible forthe inspector deter shipment verification years, as required by actiassociated sportation activities 49ubchapter e C hadnot with 49 CFR werassigned re to S qualitycontrolinspector h s vities. Specifically verifying th specific transpmined that two ra other specific transportati ,

CFR 172.704, and had ortation

\g appropriatelyperformed had expired. This Se onad verified einspector f thatpackag e found that thceived func performed consistent with Appendi or Radwastemarkings, verity LevelIV Violationi Shipments labelings, 9 activities placae tworequireo radwaste in R, Subchapter C, wer rds, and x C of the NRC 8-03 s beine;Enforce and r98-62 treated as a No afte h e

t eir training ment Policy (50-445;446/99n Cited Violation, 05-01). This

_

_. - -_. - - -

, .- -- . - -. -- -. - - -,

.

I j-6-proce%es were found to contain the appropriate level of detail for the preparation of shipment ,

l Conclusions Programmatic controls and procedures for handling, processing, and shipment of radioactive waste / materials were properly implemente R4 Staff Knowledge and Performance The inspector interviewed members of the radiation protection staff involved in radioactive waste and material transportation activities. Personnel responsible for conducting the transportation program for radioactive waste and materials were knowledgeable, experienced, and had an excellent working knowledge of the transportation regulation R5 Staff Training and Qualification in Radiological Protection and Chemistry R Trainina and Qualification of Radiation Protection and Quality Control Radwaste Personnel Inspection Scope (86750)

!

The inspector reviewed the training and qualification records of personnel responsible for the preparation and packaging of radioactive waste and radioactive materials for shipmen Observations and Findinas During a review of selected operating procedures and shipping paper documentation, the inspector noted that a radiation protection staff member prepared the package of

- radioactive matetial/ waste for shipment. The packaging and shipping documentation was than verified by an independent radiation protection staff member and a quality controlinspector to ensure regulatory requirements were satisfie The inspector verified that radiation protection staff members who were assigned to implement the solid radbactive waste processing and transportation activities were properly trained and qualified. However, the inspector determined that two radwaste quality control inspectors who were responsible for verifying specific transportation activities associated with 49 CFR Subchapter C had not received function specific training every three years, as required by 49 CFR 172.704, and had performed shipment verification activities. Specifically, the inspector found that the two radwaste quality control inspectors had verified that package markings, labelings, placards, and other specific transportation activities required in 49 CFR, Subchapter C, were appropriately performed for Radwaste Shipments 98-03 and 98-62 after their training had expired. This Severity Level IV Violation is being treated as a Non-Cited Violation, j consistent with Appendix C of the NRC Enforcement Policy (50-445;446/9905-01). This i

i

- - . - . _ - .. - _ - .- - . . - . - - . - - - - . . - . . - - - . - - .

.

,

-7-

violation was placed in the licensee's corrective action program as SMART  !

. Form 1999-00037 l

'

. Conclusions '

- Radiation protection personnel involved in the transfer, packaging, and shipping of  ;

radioactive materials and radioactive waste were properly trained and qualified. A- '

violation of 49 CFR 172.704 was identified involving the failure of two radwaste quality control inspectors to receive function specific training every three years. This violation  ;

was placed in the licensee's corrective action program as SMART Form 1999-000371; i This Severity Level IV Violation is being treated as a Non-Cited Violation, consistent with j Appendix C of the NRC Enforcement Polic i R7 - Quality Assurance in Radiological Protection and Chemistry Activities

'

R Nuclear Oversiaht Evaluation Reports Insoection Scope (86750)

Nuclear Oversight Evaluation Reports 98-000047,97-000093, and 97-000073 were

reviewe Observations and Findinas Ti.e inspector noted that the audits were performed by qualified personnel, were .

comprehensive, and effectively evaluated the solid radioactive waste and transportation of radioactive material / waste programs. Audit findings were properly captured through 4

'

- use of the facility corrective action progra Conclusions Comprehensive audits performed by qualified personnel effectively evaluated the solid l radioactive waste and transportation of radioactive material / waste program R7.2 Corrective Action Proaram

. Inspection Scope (86750)

Selected corrective action reports called SMART Forms were reviewed to evaluate the effectiveness of the licensee's controls in identifying, resolving, and preventing

. problems, Observations and Findinos Several SMART Forms concerning the solid radioactive waste and radioactive material / waste transportation programs were reviewed. These reports were initiated as needed and had a proper threshold for identifying problems. The reports were

_ _ _ .__ . . . . - __ ._ _

. . . - . . . - - - _ . _ . . _. . . -

.

-8-effectively used to track and trend problems. In general, corrective actions were timely and appeared effectiv Conclusions The corrective action process was effectively used to identify problems, perform evaluations and assessments, and implement timely corrective action V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on February 26,1999. The licensee acknowledged the findings presented. No proprietary information was identifie l

!

-_

. - - . . . . . _ - . - - - -

, i I

i

. .:

ATTACHMENT  ;

i I

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED q i

Licensee l

\

!

J. Alldredge, Radiation Protection l J J. Ayers, Plant Support Overview Manager ]

S. Bradley, Radiation Protection Supervisor i J. Curtis, Radiation Protection Manager  !

T. Hope, Regulatory Compliance Manager - l D. Kay, Radiation Protection Supervisor i K. Kilgariff, Radiation Protection 1 B. Knapp, Radiation Protection Staff J.~ Luna, Senior Radiation Protection Technician D. Moore, Operations

'C. RicVgauor, Maintenance Overview R. Sandford, Senior Nuclear Training Specialist B. Snellgrove, Maintenance Overview J. Stansbury, Senior Radiation Protection Technician -

L. Terry, Senior Vice President C. Welch, Senior Nuclear Specialist  ;

'

C. Wilkerson, Senior Licensing Engineer NRC T. Gody, Senior Resident inspector  !

S. Schwind, Resident inspector j

)

LIST OF INSPECTION PROCEDURES USED l

IP 86750 Solid Waste Management and Transportation of Radioactive Waste i

ITEMS OPENED. CLOSED. AND DISCUSSED

' Ooened and Closed j-50-445/9905-01- NCV Failure to perform required training ,

l LIST OF DOCUMENTS REVIEWED  !

'

Reports Nuclear Oversight Evaluation Report 97 000073," Radioactive Waste Sh:pments," May 29, 199 , ,

IL w ,-, , , - --er -

_ . _ .

.__

.

.

2-Nuclear Oversight Evaluation Report 97-000093,"Radwaste and Effluent / Environmental Monitoring Program," September 3,199 Naclear Oversight Evaluation Report 98-000047,"Radwaste and Effluent / Environmental Monitoring Programs," July 29,199 Procedures RPI232 Characterizing Radioactive Material for Shipment, Revision 3 RPl 234 Packaging Radioactive Material for Shipment, Revision 5 RPI 236 Loading, Shoring, and Bracing Radioactive Material Shipments, ' Revision 3 RPl 237 Placarding Radioactive Material Shipments, Revision 2

RPI 238 Radioactive Material Shipment Surveys, Revision 4

'

RPI 239 Radioactive Material Shipment Documentatior, Revision 4 RPI 254 Shipment of Radioactive Waste to Disposal Facilities, Revision 4 RPI 255 Characterizing Radioactive Waste for Disposal, Revision 3 i

RPI 256 Radioactive Waste Classification for Disposal at the Barnwell Waste Management Facility, Revision 3 RPI 259 Radioactive Waste Manifests and Documentation for Shipments to Disposal Facilities, Revision 6 RPI 260 Radwaste and Radioactive Material Container Accountability, Revision 4 STA 709 Radioactive Waste Management Program, Revision STA 713 Process Control Program, Revision 0 l

l

,

a i

- - -