IR 05000458/1994002

Insp Rept 50-458/94-02 on 940103-07.No Violations Noted. Major Areas Inspected:Radiation Protection,Solid Radwaste Mgt & Transportation of Radioactive Matl Controls

ML20059L452
Person / Time
Site:	River Bend
Issue date:	02/01/1994
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20059L449	List: IR 05000458/1994002 ML20059L446
References
50-458-94-02, 50-458-94-2, NUDOCS 9402070036
Download: ML20059L452 (20)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report: 50-458/94-02 License: NPF-47 Licensee: Entergy Operations, In P.O. Box 220

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St. Francisville, Louisiana l

Facility Name: River Bend Station Inspection At: St. Francisville, Louisiana Inspection Conducted: January 3-7, 1994 e Inspectors: A. D. Gaines, Radiation Specialist L. T. Ricketson, P. E., Senior Radiation Specialist J. B. Nicholas, Ph.D., Senior Radiation Specialist Approved: @ /'[ k [

I B.~Murray, Chief, Facili ies Inspection Date / ./ j Programs Section c -l

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Inspection Summary Areas Inspected: Routine, announced inspection of the radiation protection, solid radioactive waste management, and transportation of radioactive material programs. The inspection included a review of organization and management controls; maintaining occupational exposures ALARA; occupational radiation exposure; radioactive waste treatment, and effluent and environmental ,

monitoring; solid radioactive waste management; and transportation of l radioactive material Results:

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• Acquisition of state-of-the-art radiation protection equipment .

demonstrated management support for the radiation protection program (Section 1.1).

• New 10 CFR Part 20 was implemented on January 1, 1994. Additional guidance in some areas is needed for personnel responsible for implementing the new regulations (Section 1.1).  ;

• The radiation protection organization was sufficiently staffed with very little staff turnover (Section 1.2).

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• A good radiological deficiency reporting system was in place (Section 1.4). j

• Quality assurance audits of the radiation protection program were !

comprehensive, performed by technical experts, and responses to findings !

were timely (Section 1.5).

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• Good working relationships existed between the radiation protection organization and craft groups (Section 1.5).

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• An excellent evaluation was performed of the ALARA program by corporate .

health physics, which included excellent recommendations to' improve the ALARA program (Section 2.1). q

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• Poor attendance by members at the ALARA committee meetings and low *

individual involvement in the ALARA program and ALARA suggestion program

were noted (Sections 2.1 and 2.3).

• ALARA dose goals were set and tracke The 1993 acal was exceeded due

to unplanned outages (Section 2.4).

• Collective dose 3-year averages were high. A high person-rem value is b projected for 1994 (Section 2.5). {

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• Appropriati steps were taken to reduce dose, one of which was the source '

term reduction program (Section 2.5).

• New senior radiation protection technicians met qualification ,

requirements (Section 3.1).

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• A good radiation protection training program was implemented with qualified instructors (Section 3.1). .!

• A standardized screening examination was used in the selection of contract radiation protection technicians (Section 3.1). ];

• Professional advancement of radiation protection technicians was :

encouraged (Section 3.1). l

• The training program for supervisory and professional' personnel was not completely comprehensive (Section 3.1). . ;

• A good personnel dosimetry program was maintained (Section 3.2). I i

e Posting of radiation areas and control of locked high radiation areas

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were excellent (Section 3.2). l

• Appropriate revisions were made in the internal exposure control- program- )

in order to implement new 10 CFR Part 20 requirements (Section 3.3). ,

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f l-3- a a Licensee personnel demonstrated competence in calculating internal radiation. doses.(Section 3.3). ,

• Housekeeping, during routine operations, was excellent (Section 3.5).

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• A good rating program was in place for safety-related air cleaning systems (Section 4.1).

• Semiannual Radioactive. Effluent Release Reports were submitted in a timely manner and contained all the required information in the proper format (Section 4.2).

• The radwaste operations department organizational structure and staffing ,

met requirements (Section 5.1).  ;

• The radwaste operations department had experienced no turnover o ,

supervisory personnel during the past 1 1/2 yearsL (Section 5.1).

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• A good training program.for radwaste. operations. department personnel had been implemented (Section 5.2).  ;

• The radwaste operations department had an adequate, well qualified staff to meet shift staffing requirements and perform solid radioactive waste activities (Section 5.2). ,

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• Good quality assurance audit.and surveillance programs of the Process Control Program, solid radioactive waste management program, and transportation activities were implemented (Section 5.3). ,

• Quality assurance audits were performed of the contractors used to perform solid radioactive waste processing and volume reduction services and safety-related air cleaning systems' surveillance testing (Section 5.3).

• An effective solid radioactive waste management program was bein implemented (Section 5.5). ,

• Excellent ALARA procedures were implemented by radwaste personnel (Section 5.5), i

• Excellent implementing procedures that addressed waste classificationi '

and characterization, selection of packages,- preparation of packages,- [

and delivery of the completed packages to the carrier were maintained' >

(Section 5.6).

• Personnel responsible for the shipment and transportation of radioactive waste or materials were knowledgeable of the regulatory requirements and j burial site license conditions (Section 5.7.3). j

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-*. Attachment -Persons Contacted and Exit Meeting ,

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h-5-DETAILS 1 ORGANIZATION AND MANAGEMENT CONTROLS (83722) ,

The licensee's program was inspected to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with the commitments in Chapter 13 of the Updated Safety Analysis Repor ,

1.1 Changes There were no significant changes to the organizational structure of the radiation protection progra New equipment procured by the licensee included a new scanning whole-body-counter, a bulk radiation monitor for use on items being removed from the radiological controlled area, and a digital camera system which will be used -

to produce pictures of equipment with dose rate information superimposed on them. The pictures will be included with the job plans and reviewed by craft  :

personnel during their preparation for the wor Procedures were revised for the implementation of new 10 CFR Part 20 provisions. The inspectors noted that the new procedures were not installed in the controlled procedure sets in the plant until January 4, 1994, and were not placed in the controlled set of procedures in the training department until January 6, 1994. The inspectors determined that this was within the licensee's procedural requirements for distributing procedure revision ,

Licensee representatives pointed out that a book containing official work copies of the new procedures was in the radiation protection offic '

The inspectors reviewed selected examples of the latest revisions of the procedures. Overall, the procedures provided appropriate guidance. However, the inspectors noted that neither the radiation work permit implementing ,

procedure nor the respiratory protection program implementing procedure ~ ,

contained clear guidance for determining the need for respiratory protection ,

equipment to aid radiation protection technicians who prepared radiation work permits. The radiation protection technicians interviewed by the inspectors knew, generally, that respiratory protection equipment will be used less under the provisions of new 10 CFR Part 20, but they could not specifically stat '

the circumstances under which the equipment would be required. They acknowledged a need for more guidance. Licensee representatives stated thati they were preparing such guidance but had not completed it by the January 1, ,

1994, implementing dat .

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With the implementation of new 10 CFR Part 20 regulations on January 1,1994, there were significant changes in the internal exposure control progra These changes are addressed in Section :

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-6- y 1.2 Staffino Staffing was appropriate and remained stable with low turnover. -Two radiation protection technicians moved to other licensee programs, but none left the licensee's employmen i The _ radiation protection organization utilized some contract personnel. - The radiological operations group employed eight contract radiation protection ;

technicians for job coverage, because a corresponding number of permanent ,

staff members were assigned to outage planning and preparation dutie .3 Radiation Protection Manaaer The duties of the Radiation Protection Manager were being filled by the Radiation Protection Supervisor. (See NRC Inspection Report 50-458/93-12 for backgroundinformation.) For example, procedures issued to implement new 10 CFR Part 20 were reviewed and signed by the Radiological Protection Superviso ,

1.4 Identification and Correction of Weaknesses There were 130 radiological deficiency reports submitted in 1993. Causes of

the events were trended and reviewed by management. Radioactive material control problems constituted 45 percent of the problems documented. Al though not typical, Radiological Deficiency Reports 93-0099 and 93-0105 were examples ,

in which corrective actions had not been taken by the required response date Late notices were forwarded to the responsible manager in these case Overall, the radiological deficiency reporting system functioned appropriately to track, trend, and correct radiological problem .5 Audits and Appraisals

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Quality Assurance Audit 93-08-I-HPRP, performed August 16 through September 3, ,

1993, was reviewed by the inspectors. The lead auditors were permanently assigned to the areas audited, ensuring continuity and accumulation of experience. The audit teams included onsite technical experts and technical i experts from other nuclear power facilities. Additional quality assurance l personnel on the teams were qualified auditors. The audits identified problem _ ;

areas and made suggestions for improvement. Responses to the findings were '

made within the time period allowed by the' licensee's quality _ assurance

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The inspectors noted that the radiation protection group implemented a program of site tours and observations by supervisors and professionals in order to identify radiological problems in the plan Personnel performed observations on a rotating schedule and documented the results. The results were reviewed ,

by the Radiation Protection Supervisor and the Director of Radiological  ;

Programs. The program was identified as a good management too ,

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The inspectors also noted that assessments by corporate personnel were '!

performed in the areas of ALARA and new 10 CFR Part 20 readines '

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The inspectors interviewer. supervisors of mechanical maintenance, electrical i'

maintenance, and instruments and controls with regard to their assessments of the performance of radiation protection personnel. The supervisors stated i they had noted an improvement in the performance of the radiation protection i group and that relationships between their organizations and radiation ,

protection was goo ;

1.6 Conclusions

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Acquisition of state-of-the-art equipment demonstrated management support for the radiation protection progra The licensee implemented new 10 CFR Part 20 on January 1,1994, although additional guidance in some areas would be appropriat .

The radiation protection organization remained sufficiently staffed. There was very little staff turnove i A good radiological deficiency reporting system was in place. The program provided useful information to radiation protection management concerning radiological problems and served to ensure that corrective actions were take v Quality assurance audits of the radiation protection program were comprehensive and relied on experienced personnel including technical experts from other nuclear power facilitie The radiation protection organization's _ ,

responses were provided within the required response periods and appropriately ,

addressed the finding '

The relationship between the radiation protection organization and craft groups was goo MAINTAINING OCCUPATIONAL EXPOSURES ALARA (83728)

The ALARA program was inspected to determine compliance with 10 CFR Part 20 [

and Technical Specification ;

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2.1 Audits and Appraisals The inspectors reviewed a draft of an ALARA program evaluation report. The i

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evaluation of the River Bend Station ALARA program was performed during the period November 12-19, 1993, by two individuals from Entergy Operations ,

Corporate Health Physics and an individual who worked in the ALARA ,

organization at another Entergy plant. The evaluation was excellent an "

provided pertinent observations.and recommendations to irprove the ALARA program. An important observation noted by the evaluatian team was that

" station personnel ownership of the ALARA program and the communication of upper management's ALARA expectations need improvement.' The evaluation i contained other observations which were also noted_by the inspectors, such as,.

poor attendance by members at ALARA committee meetings and low personnel involvement in the ALARA program and the ALARA suggestion program. The evaluation included excellent recommendations for improvement of the ALARA program, some of which included designating the Plant Manager as the ALARA f-

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-8-committee chairperson and requiring more participation in the setting of ALARA goals by department manager .2 ALARA Program Changes j The inspectors discussed changes in the ALARA program with licensee personnel :

and noted that no major changes had occurred since the last NRC inspection of this are .3 Worker Awareness and Involvement .i The inspectors discussed the ALARA program with several workers and reviewed the ALARA suggestion program. The discussions with workers and the review of

..the ALARA suggestion program indicated that awareness and' involvement in the ALARA program was low. The interviews indicated that the workers knew tha ALARA meant "as low as reasonably achievable"; however, they thought that the responsibility for being or doing things ALARA was accomplished by individuals ,

in the radiation protection department. This indicated low worker awareness and involvement in the ALARA program. The individuals interviewed were also ,'

not completely aware of the ALARA suggestion program. The ALARA suggestion-program only received 15 suggestions in 1993 which also indicated low worker l

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2.4 ALARA Goals and Objectives Person-rem goals were set and tracked by the licensee including departmental

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goal s . The licensee's goal for 1993 was 90 person-rem. The licensee expended i j

approximately 186 person-rem in 1993. The 90 person-rem goal was set for

normal operations with no unplanned outages which would last over 2 weeks. In l April 1993, because of problems with equipment, a 9-day. planned outage was i extended to 63 days with a total of 69.5 person-rem expended. Another forced outage starting in July lasted 21 days and expended 17-person-rem. The licensee also had unexpected repeated problems with repairs to the reactor water cleanup pumps that expended 25.5. person-rem. The licensee performed a '

calculation which showed that if the dose for the. unplanned outages and equipment repairs were subtracted from the final total, and normal operational {

dose was substituted for the time of the outage and equipment repairs, that- !

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they would have met their goal and only expended approximately 86 person-rem for 199 {

2.5 ALARA Results ,

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The licensee's collective dose 3-year rolling averages were reviewed. The :

3-year rolling average for 1990, 1991, and 1992 was 448 person-rem. The 1992 ,

average dose per reactor for the 37 operating boiling water-reactors was 360 person-rem for 1992. The licensee's collective dose for 1992 was 710 person-l rem, which included an extended outage. The collective dose for 1992 made the L licensee's three year rolling averages high. The licensee's goal for 1994 is 650 person-rem which includes an outage in 1994. This will further increase the 3-year rolling average for 1992.1993, and 1994 to approximately 515 person-re >

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-9-The licensee had taken steps to reduce their collective dose, one of which was >

their source term reduction program. During the 1994 outage, some of the work that will decrease the source term is the installation of antirotational devices on the main steam isolation valves, replacement of low pressure turbines with low cobalt and low stellite turbines, and valve replacement with non-stellite valves. Other dose reduction techniques that will be used du_ ring ,

the 1994 outage include: flushing of nozzles before repair work is started, ;

expanded use of the teledose system, lifting the-separator and dryer wet, and ;

the use of remote air sampler ,

2.6 Conclusions An excellent evaluation was performed of the ALARA program by corporate health physics. The evaluation had excellent recommendations to improve the ALARA progra Poor attendance by members at the ALARA committee meetings and low individual involvement in the ALARA program and ALARA suggestion program were noted. ALARA dose goals were set and tracked; however, the goal was exceeded for 1993 due to unplanned outages. Collective dose 3-year averages were high due to an extended outage in 1992. The licensee had taken appropriate steps to reduce dose, one of which was the source term reduction progra ,

3 OCCUPATIONAL RADIATION EXPOSURE (83750)

The licensee's program was inspected to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with the commitments in Chapter 12 of the Updated Safety Analysis Repor .1 Training and Qualifications The inspectors reviewed resumes of radiation protection technicians who were hired since the previous NRC inspection and determined that they met the qualification requirements. The inspectors confirmed that a  :

task / qualification matrix was available to radiation protection foremen and supervisors to aid them in selecting personnel for specific task :

The inspectors interviewed training representatives and determined that- !

continuing training for radiation protection technicians emphasized lessons ;

learned, particularly, in the radioactive materials control are t A standardized screening examination was used for the selection of contract radiation protection technicians. The contract radiation protection , !

technicians were required to demonstrate their knowledge of the licensee's ,

procedure One instructor position in general employee training was vacant for 6 month Another instructor position in radiation protection technician training was vacant for approximately a year; however, a contract instructor was used for i approximately 8 months to supplement the training staff in this are The inspectors reviewed the training program for supervisors and professionals-in the radiation protection organization and noted that all personnel in this

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L -10-category had received training in their particular specialties, except the Radiation Protection Superviso Eight members of the radiation protection organization were registered by the National Registry of Radiation Protection Technologists. Two radiation protection technician instructors were also registered. No one was tested or registered in 1992, because the plant was in an outage when the registration examination was given. Fifteen people took the registration examination in

! November 1993 and were awaiting the results. The licensee. encouraged L radiation protection technicians to take the examination by reimbursing them for the cost of the examination and by presenting examination preparation trainin .2 External Exposure Control The inspectors toured the radiological controlled area and reviewed area postings, performed independent radiation measurements, and noted that all posting was correct and easy to understand. The inspectors also reviewed locked, high radiation areas and determined that they were properly controlle There was no major change in the dosimet y equipment. The licensee will modify the dose algorithm for eye dose in preparation for the first thermoluminescent dosimeter processing to be performed in accordance with the new 10 CFR Part 2 .3 Internal Exposure Control In preparation for the implementation of the new 10 CFR Part 20 requirements regarding internal exposure, the licensee conducted a prospective assessment of the likelihood that workers would exceed 10 percent of 'an annual limit on intake (documented in Radiation Policy Guide M-93-512) and determined that -

they would not. The bases for this conclusion were the assumption-that the uses of radioactive material would not change and that historical, worst-case data showed that no one had previously exceeded the equivalent of 10 percent of an annual limit on intak As~ a result of the assessment, the licensee concluded that a formal internal monitoring program was no longer required. Therefore, annual whole-body counting and breathing zone air sampling for the purpose of derived air concentration-hour assignment were discontinued. Instead, a " passive internal monitoring" program, utilizing the gamma-sensitive, portal monitors will be used. The licensee's radiation policy guide (RPG-M-93-524) stated that portal monitors were capable of detecting the equivalent of 1 percent of an annual-limit on intake of the normal plant mix of radioactive materia Special whole-body counting will be performed when significant intakes (defined as greater than 1 percent) are identified. Air sampling will be used to determine the potential for intak The licensee's radiation policy guide and respiratory protection programs, implemented by Procedure RSP-0201, Revision 6, stated that special whole-body rmts will be performed to measure the effectiveness of the progra . - _ _ - _ - _ - _ _ _ _ _ _ _ _ - _ _ - _ _ -

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However, when interviewed, licensee representatives stated that the specific j guidance for selecting individuals to receive the special whole-body counts :

for the purpose of measuring the effectiveness of the program had not been '

finalized or formalize !

The inspectors proposed hypothetical situations involving internal exposures, and the licensee's . representative performed internal dose calculations. The ';

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licensee and NRC's results were in agreement. The. implementing procedure provided appropriate guidance. The licensee had no computer software for ,

calculating internal dose, but they intended to procure on l P

The inspectors determined that the whole-body counter was last calibrated o July 31, 1993. There were six intakes of radioactivity in 1993. The largest i amount of activity indicated by whole-body counting was 60 nanocuries of ;

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3.4 Control of Radioactive Material and Contamination. Surveying, and .

Monitorina During tours of the radiological controlled area, the inspectors noted .i

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excellent housekeeping prsctices and extensive efforts by the licensee to control tools and materia ;

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The inspect 9rs reviewr;d personnel contamination. reports and determined that they were complete ar.d that proper actions were taken in response to the event .

There were 58 skin contamination events in 199 For+.y-three events required j skin dose calculations to be performed. All of these events wo e the result 1 of discrete particles. The highest dose assessed was 2.189 rem :

The P.adiological Health Instrument group assumed the responsibility for calioration of the portal monitors. Previously, the Instruments and Controls group performed this functio !

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3.5 Conclusions New senior radiation protection technicians met qualification requirements. A :

good training program was implemented with qualified instructors. A t standardized screening examination was used in the selection of contract !

radiation protection technician Professional advancement of radiation ,

protection technicians was promoted. The training program for supervisory and j professional personnel was not completely comprehensiv Posting of radiation areas and. control of locked high radiation areas was excellent. No significant changes in the dosimetry program were note j i

Significant changes were made in the internal exposure control program as a i result of the implementation of the new 10 CFR Part 20 requirements. Licensee J personnel demonstrated competence in calculating internal radiation dose Housekeeping, during routine operations, was excellen ]

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-12-4 RADI0 ACTIVE WASTE TREATMENT AND EFFLUENT AND ENVIRONMENTAL MONITORING (84750)

4.1 Air Cleaning S_ystems The inspectors reviewed the safety-related air cleaning systems testing program to determine agreement with the commitments in Chapters 7 and 9 of the Codated Safety Analysis Report and to determine compliance with the requirements in Technical Specifications 3/4.6.5.4,.3/4.6.5.6, and 3/4. The inspectors reviewed selected records and the _ results of surveillance testing of the safety-related air cleaning systems which contained high efficiency particulate air filters and activated charcoal adsorbers. 'The :

inspectors verified that the surveillance tests included the required periodic functional checking of the ventilation systems' components, evaluation of the high efficiency particulate air filters and activated charcoal adsorbers, and the replacement and in-place filter testing'of the' filter systems. Selected records and surveillance test results for the period January 1992 through December 1993 for the standby gas treatment system (Trains A and B), the fuel '

building ventilation system (Trains A and B), and the main control room air conditioning system (Trains A and B) were reviewed. The in-place filter-testing and activated charcoal adsorber laboratory tests had been performed in accordance with approved procedures by a contractor, and all' surveillance test results were verified to be within Technical Specification limits ^. The inspectors noted that the Technical Specification requirement for testing th various ventilation systems' activated charcoal adsorber material after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation was being tracked by the control room. operators on the appropriate run time surveillance logs for each ventilation filter. trai ,

4.2 Reports of Radioactive Effluents and Radioactive Waste Shipments The inspectors reviewed Semiannual Radioactive Effluent Release Reports to determine compliance with the requirements of.10 CFR Part 50.36(a)(2) and Technical Specifications 6.9.1.8, 6.13, and 6.1 The inspectors reviewed the Semiannual Radioactive Effluent Release Reports ;

for the time period January 1, 1988, through December 31, 1992. These reports

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were written in the format d2 scribed in NRC Regulatory Guide 1.21, Revision 1,

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June 1974, included the information required by the Technical Specifications and provided a summary of the radioactive solid waste shipped from the station for_ processing and/or burial. The inspectors noted that the licensee had ,

amended the Technical Specifications in 1993 to change the frequency of the Radioactive . Effluent Release Reports from semiannual to' annual beginning-with ,

the 1993 Radioactive Effluent Release Report. The inspectors reviewed the .

last changes to the Process Control Program (RWS-0204, Revision 4) made in April 1991 and found the changes documented in the appropriate Semiannual Radioactive Effluent Release Report as. required by the Technical ,

Specifications. The Process Control Program had recently been revised and was currently in the review proces Revision 5 consisted of- minor editorial changes and the deletion of three vendor solidification procedures that were no 1onger in us l

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- inspectors reviewed the licensee's records for shipment of solid low-level radioactive waste and noted that the licensee had completed'332. radioactive >

waste shipments by exclusive use vehicle to burial sites in South Carolina and Nevada and to a waste processing site in Tennessee. The licensee'had not made any shipments of spent fuel. The following table summarizes the total volume and curie content of the solid low-level radioactive waste shipped for the period 1988 through 199 ,

Year Shipments ~ Volume' -Curie. Content? '

Cubic Feet 1988 45 10,792.48 349.99 1989 67 15,773.40 840.82 i 1990 38 8,471.53 401.72 >

1991 28 5,524.79 89.27 I 1992 126 15,129.26 689.38 1993 28 20,842.00 152.70

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4.3 Conclusions Safety-related air cleaning systems were tested in accordance with Technical Specification requirements, and all test results were within Technical ;

Specification limit j Semiannual Radioactive Effluent Release Reports were submitted in a timely manner, and these reports contained all the required information presented in the recommended format. Changes to the Process Control Program were properly documente SOLID RADI0 ACTIVE WASTE MANAGEMENT AND TRANSPORTATION OF RADI0 ACTIVE MATERIALS (86750)

i The inspectors reviewed the solid radioactive waste management and- l transportation of radioactive materials programs to determine agreement with commitments in Chapters 13 and 17 of the Updated-Safety Analysis Report and in-the licensee's response to NRC Bulletin 79-19; and compliance with the >

requirements in Technical Specifications 6.2, 6.3, 6.4, and 6.5.3.8; 10 CFR '

Parts 20, 61, and 71; and 49 CFR Parts 172-18 'I 5.1 Organization and Management Controls  !

The inspectors verified that the organizational structure of the radwaste operations department was as defined in the Updated Safety Analysis Report and Technical Specifications. Management control procedures were reviewed for the assignment of responsibilities for the management and implementation of the '

radioactive waste management program. The radwaste operations department was

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responsible for performing the radioactive waste effluent releases and the processing, packaging, and shipping of radioactive waste and materials. The ,

inspectors determined that the duties and responsibilities.of the radwaste operations department were-being implemented as specified in station ,

procedures. The radwaste supervisor, four radwaste foremen, ten senior nuclear equipment. operators, and six contract laborers composed the radwaste operations department staffing which were directly responsible for processing, packaging, and shipping of radioactive waste and materials. The ten senior- :

nuclear equipment operators staff five rotational shifts. The inspectors

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interviewed several members of the radwaste operations staff'and determined that they were familiar with the requirements of the radioactive waste program and maintained a high level of performanc >

The inspectors reviewed the staffing of the.radwaste operations department i since the previous NRC inspection of the radioactive waste management program conducted in April 1992 and determined that the radwaste operations department was adequately staffed in accordance with licensee commitments. There had ,

been no turnover of personnel except for the rotating shift senior nuclear equipment operators within the radwaste operations departmen !

5.2 Training and Qualifications The inspectors reviewed Radwaste Procedure RWS-0203, " Personnel Qualifications for Radwaste Section," Revision 5, issued November 6, 1990, and the training records and qualification cards for the radwaste supervisor, four radwaste foremen, ab.i selected senior nuclear equipment operators currently involved in the solid radioactive waste and radioactive materials processing and transportation activitie Based on the review, it was verified that the radwaste supervisor, the four radwaste foremen, and the ten senior nuclear ,

equipment operators currently responsible for performing solid radioactive waste program activities had completed the required training to perform their assigned duties. It was also noted that the radwaste supervisor and the four radwaste foremen had recently completed on-site regulatory and radioactive material management computer software training to meet response commitments to

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NRC Bulletin 79-19. The inspectors determined that personnel responsible for *

solid radwaste and transportation activities were knowledgeable of the applicable NRC, Department of Transportation, and burial site license condition .3 Quality Assurance Program The inspectors reviewed the quality assurance audit and surveillances of the Process Control Program and the radioactive waste management program and the qualifications of the quality assurance auditors and technical specialists who

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performed the audit and surveillances. The audit was in compliance with the *

Technical Specification audit frequency requirement The report of the quality assurance audit performed since the previous NRC inspection of the solid radioactive waste and transportation programs conducted in April 1992 was reviewed for scope, thoroughness of program '

evaluation, and timely followup of identified deficiencie The audit was '

performed in accordance with quality assurance procedures and schedules by i

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.- l-15-qualified auditors and technical specialists. Quality Assurance Audit 92-10-I-PCON/RWMP, " Process Control /Radwaste Program," conducted October ,

26 through November 6, 1992,. reviewed the adequacy and effectiveness of the !

Process Control Program and the radioactive waste management program. The _

audit verified that the processing, packaging, and shipping of solid  !

radioactive waste and materials were being performed and documented in _

accordance with regulatory and Technical Specification requirements. No audit .!

findings were identified; however, four program improvement concerns were- i generated as a result of this audit and documented in Quality Conditio !

Reports P-92-11-019 through P-92-11-022. The Quality Condition Reports and the licensee's-responses-were reviewed by the inspectors and were foun satisfactory. Responses to the Quality Condition Reports were made within the time period allowed by the licensee's quality assurance procedures and were closed. The quality assurance audit of the Process Control Program and solid ;

radioactive waste management program was of good quality and satisfactory to ,

evaluate the licensee's performance in implementing the radioactive waste management program and meeting Technical Specification requirement l The inspectors reviewed four quality assurance surveillances performed during the time period January 1993 through May 1993 in the areas related to the ;

performance of the radioactive waste management program. Quality Assurance

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Surveillance OS-93-01-03, "Radwaste Shipment," was performed on January 13, .

1493, and monitored a laundry shipment (93-0001). All activities with regard !

to this shipment were conducted in accordance with regulatory requirement There were no findings or observations identified. Quality Assurance Surveillance OS-93-02-02, " Radioactive Waste Management Program," was performed on February 5,1993, and included an overall review of the radioactive waste management program and the qualifications of radwaste i operations personnel. One Quality Condition Raport was issued as a result of !

the surveillance. Response to the Quality Condition Report was made within the time period allowed by the licensee's quality assurance procedures _ and was ,

closed. Quality Assurance Surveillance OS-93-04-03, "Radwaste. Shipment .

(DAW /LSA . Shipment for Compaction)," was performed on April 8,1993, and J included monitoring the performance of radwaste and radiation protection personnel during the preparation of a shipment of dry active waste drums for volume reduction. All activities with regard to this shipment were conducted -

in accordance with regulatory requirements. There were no findings or observations identified. Quality Assurance Surveillance 0S-93-05-19, i

"Radwaste Shipment (Laundry)," was performed on May 24, 1993, and monitored Laundry' Shipment 93-0033. All activities with regard to this shipment were- ;

conducted in accordance with regulatory requirements. There were no findings j or observations identifie ,

The licensee used a contractor to provide various radwaste services such as- !

incineration, compaction, wet waste processing, solidification, and shipment '

of solid radioactive waste for burial after processing and volume reductio The licensee also used a contractor to perform in-place filter testing and ;

laboratory charcoal adsorber analyses on the station's safety-related air ;

cleaning systems. The licensee used an audit of the solid radioactive waste !

processor performed by a Nuclear Procurement Issues Committee audit team 1 during the time period July 10-12, 1990, and an audit of the air cleaning '

systems filter testing contractor performed by a Nuclear Procurement Issues ,

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-16-Committee audit team during the time period March 13-14, 1991, to evaluate the performance of the contractors to perform their respective functions and to retain their current status on the licensee's qualified suppliers list. The inspector reviewed these audits performed on the two contractors and determined that the audits were satisfactory to evaluate the contractors'

abilities to perform their respective activities. The inspector verified that the licensee had also performed annual evaluations of the contractors'

programs as required to retain their current status on the licensee's qualified suppliers lis .4 Changes to the Solid Radioactive Waste Management Program The inspectors reviewed changes that had been made since the last NRC inspection in facilities, equipment, program, and procedures that might affect the solid radioactive waste management program. The licensee had not made any major changes to the program since the previous NRC inspection conducted in April 199 .5 Solid Radioactive Waste Management The inspectors reviewed the licensee's solid radioactive waste program to determine agreement with commitments in Chapter 11 of the Updated Safety Analysis Report and compliance with the requirements in Technical Specifications 3/4.11.3, 6.13, and 6.1 The inspectors noted that the licensee used two methods to dispose of dry active waste One method was to place the dry active waste into a sea-land container and ship it offsite to a vendor who would segregate and incinerate for volume reduction. The second method used the licensee's compactor which was used to compact dry active waste into 55 gallon metal drums which were shipped offsite to a vendor who then further reduced the waste volume by super compactio The inspectors observed the licensee filling a high integrity container with spent resin and the dewatering of the resin in preparation for shipment to a radioactive waste burial site. Excellent ALARA procedures were implemented by the personnel performing the resin transfer and the filling and dewatering of *

the high integrity container. The spent resin transfer and the filling and dewatering process were performed remotely and monitored by video camer The licensee was in the process of reviewing the design for an interim onsite ,

storage facility for radioactive waste material .6 Radioactive Waste Classification, Waste Characterization, and Shipping Requirements ,

The inspectors rev uwed the licensee's program for the control, classification, characterization, and shipment of solid low-level radioactive !

waste and disposal site license conditions to determine compliance with the 1 requirements of 10 CFR Parts 20.311, 61.55, and 61.56, and the recommendations l of NRC Branch Technical Position, Revision 1, " Papers on Low-level Radioactive Waste Classification and Waste Form."

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-17-The inspectors determined that the licensee had made shipments to a contractor ;

laboratory during 1992 and 1993 of samples from specific solid radioactive waste streams for special analyses to determine scaling factors for those radionuclides which the licensee was not capable of directly measuring. The Class A waste was sampled and analyzed biennially, and the Class B waste was sampled and analyzed annually. The' inspectors reviewed the licensee's records l for selected samples and analyses of solid radioactive waste. streams and ;

scaling factor information generated for characterizing the solid radioactive

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waste prior to shipment to meet 10 CFR Part.61 requirement The inspectors reviewed selected radioactive waste shipping manifest forms and ;

shipping papers that accompanied each shipment of radioactive waste and :

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determined that the shipping manifests satisfied the requirements of 10 CFR 20.31 ,

5.7 Transportation Activities

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5. Quality Assurance Program

The inspectors verified that the licensee had received NRC Form 311, " Quality Assurance Program Approval," which provided NRC approval that the licensee's ;

submitted quality assurance program complied with 10 CFR Part 71, Subpart . Procurement and Selection of Packages l The inspectors reviewed the licensee's procurement of Department of I Transportation and NRC-certified containers. The licensee used strong-tight containers (Department of Transportation Specification 7A? Type A) for the shipment of low specific activity dry active waste and laundry. Of the 85 shipments made in 1993, 17 shipments were for burial of dewatered resins ;

shipped in high integrity containers placed inside 14-215H casks for shipment -

to the burial site. Thirty-six shipments of laundry were mad The remaining

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radioactive materials shipments were of dry active waste, chemistry samples, or uncompacted radioactive materials that were being shipped to a contractor.-

The licensee maintained current documentation on the manufacturer's design testing, maintenance, and NRC Certificate of Compliance for all radwaste .

certified containers and casks used by the licensee. The-inspectors verified !

that the licensee was on the user's list for all NRC-certified packages use +

A review of the licensee's procedures and shipping records and discussions '

with the radwaste personnel indicated the cask's manufacturers handling and loading procedures were used in preparing casks for shipmen .

i 5.7.3 Preparation of Packages for Shipment j The inspectors verified that the licensee had procedures and checklists for i the preparation of radioactive waste or materials shipments. 'These procedures !

provided for visual inspection of the package prior to filling the container, :

instructions for closing and sealing the container, marking and labeling i requirements, and determining compliance with radiation and contamination !

limits. The licensee routinely used a checklist to assure that procedures were followed, and that packages were prepared properly for shipment in ,

accordance with NRC, Department of Transportation, state, and burial site '

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l l-18-requirements. Discussions with personnel involved in the preparation of packages of radioactive waste materials for shipment indicated that they possessed an excellent knowledge of the licensee's procedures andiNRC and ;

Department of Transportation regulations pertaining to the preparation of packages for shipmen . Delivery of Completed packages to Carriers The inspectors verified that the licensee's procedures included the required NRC and Department of Transportation regulations. A review of selected records and shipping papers for radioactive waste shipments indicated that the licensee had prepared appropriate manifests and shipping papers in accordance +

with approved procedures ("Radman" computer software),.and that the shipping-papers included the necessary information to comply with regulatory l requirements. The licensee used only exclusive use carriers for all ',

radioactive waste shipments and assured that the'following items were in '

accordance with NRC and Department of Transportation regulations and station procedures: radiation levels were'within required limits, transport vehicles were placarded properly, surface contamination on packages did not. exceed requirement levels, and blocks and/or braces were in place to prevent damage or shifting of the load during transi The inspectors observed the licensee loading two sea-land containers of dry active waste on an exclusive use vehicle for shipment to a waste processing l contractor. The shipment was prepared and made in compliance with NRC and Department of Transportation regulation .7.5 Records, Reports, and Notifications a

The inspectors reviewed selected records of four different types of waste ;

shipments made by the licensae during 1993. The shipments were adequately 'I documented to meet NRC and Department of Transportation regulations. The licensee maintained records of all radioactive waste or material shipments as required. The records included all shipping-documentation, radiation surveys, and required notification informatio .8 . Conclusions ,

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The radwaste operations department organizational structure and staffing met Technical Specification requirements. The radwaste' operations department had :

experienced no turnover of supervisory personnel during the past 1 1/2 year ,

A good training program for the radwaste operations department personnel had .

been implemented. The radwaste operations department had an adequate, well I qualified staff. to meet shift staffing requirements and perform soli .l radioactive waste activitie .j i

A quality assurance audit of the Process Control Program and radioactive wr ite '

management program was performed as required. The audit was technically comprehensive and provided good program evaluation and management oversigh . . - - .

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-19-In addition, good quality assurance surveillances which monitored solid radioactive waste management program and transportation program activities were performe Audits and evaluations of the contractors used to perform solid radioactive waste processing and volume reduction services and safety-related air cleaning systems' surveillance testing were performed as required to retain the contractors' current status on the . licensee's qualified suppliers lis An effective solid radioactive waste management program was being implemente Excellent ALARA procedures were implemented by radwaste personnel. Excellent implementing procedures that addressed waste classification and characterization, selection of packages, preparation of packages, and delivery of the completed packages to the carrier were maintaine The quality assurance program for radioactive material packages was NRC '

approve Personnel responsible for the shipment and transportation of radioactive waste or materials were knowledgeable of the regulatory requirements and burial site license condition Shipments of radioactive waste or materials met applicable transportation requirement .

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ATTACHMENT ,

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1 PERSONS CONTACTED 1.1 Licensee Personnel  !

• L. Biggs, Supervisor, Operations Quality Control

• J. B. Blakley, Director, Predictive Programs

• 0. P. Bulich, Director, Licensing

• R. G. Easlick, Supervisor, Radwaste

• E. C. Ewing, Assistant Plant Manager, Maintenance >

• C. L. Fantacci, Supervisor Radiological Engineering

• J. J. Fisicaro, Manager, Safety Assessment and Quality Verification

• K. D. Garner, Licensing Engineer

• K. J. Giadrosich, Director, Quality Assurance

• J. R. Hamilton, Manager, Engineering W. C. Hardy, Radiation Protection Supervisor  :

D. L. Jarrell, Radwaste Foreman  !

• T. R. Leonard, Manager, Engineering / System Engineering 1 C. A. Lewis, Radwaste Foreman

• D. N. Lorfing, Supervisor Nuclear Licensing '

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• M. Malik, Supervisor, Operations Quality Assurance

• W. H. O' Dell, Director Radiological Programs  !

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• J. P. Schippert, Assistant Plant Manager, Systems Engineering

• M. B. Sellman, Plant Manager '

W. H. Spell, Health Physicist J. F. Spratley, Radwaste Foreman

• K. E. Suhrke, Manager, Site Support K. W. Varnado,. Radiological Engineer  ;

• J. E. Venable, Assistant Plant Manager, Operations

• A. D. Wells, Radiation Health Supervisor R. A. Wilson, Radwaste Foreman

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1.2 NRC Personnel  ;

• J. Paulk, Reactor Inspector *

• F. Runyan, Reactor Inspector

• F. Smith, Senior Resident Inspector, River Bend Station

• Denotes personnel that attended the January 7, 1994, exit meeting. In addition to the personnel listed above, the inspectors contacted other personnel during this inspection period, o i I

2 EXIT MEETING An exit meeting was conducted on January 7, 1994. During this meeting, the inspectors reviewed the scope and findings of the inspection. The licensee did not identify as proprietary, any of the materials provided to, or reviewed i by, the inspectors during the inspectio t

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