IR 05000458/1997003
| ML20210T256 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 09/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20210T246 | List: |
| References | |
| 50-458-97-03, 50-458-97-3, NUDOCS 9709150029 | |
| Download: ML20210T256 (17) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION-
REGION IV
Docket No.:
50-458 License No.:
NPF-47 Report No.:
50-458/97 03 Licensee:
Entergy Operations, Inc.
Facility:
River Bend Station Location:
5485 U.S. Highway 61
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St. Francisville, Louisiana Dates:
August 4-8,1997 Inspectors:
J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch
Michael P. Shannon, Radiation Specialist Plant Support Branch Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENT:
Supplemental Information 9709150029 970910 PDR ADOCK 05000458 o
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2-EXECUTIVE SUMMARY River Bend Station NRC Inspection Report 50-458/97-03 This announced, routine inspection reviewed the implementation of the solid radioactive
- waste management and the radioactive waste and materialc transportation programs.
Training, procedural guidance, and quality assurance oversight were also reviewed.
Plant Sunnort Overall, a good solid radioactive waste management program was implemented.
- The licensee effectively reduced the volume and radioactivity of solid radioactive waste generated (Section R1.1).
In general, solid radioactive waste was properly classified and characterized for
shipment and disposal. However, two violations were identified for the failure to obtain biennial Type A waste stream samples and to classify and che acterize dry active waste (Section R1.1).
A good transportation program for radioactive materials and radioactive waste was
maintained. Generally. shipments of radioactive materials were made consistent with the latest revisions to the Department of Transportation and NRC regulations.
However, a violation was identified for the failure to record the correct quantity and total radioactivity of a radioactive waste shipment (Section R1.2).
The radiological materials control section was adequately staffed with properly
trained and qualified personnel (Section R4).
The training program properly addressed the revisions to the transportation
regulations. All personnel participating in the preparation and packaging of radioactive waste and radioactive materials were appropriately trained (Section RS).
Proper staffing was maintained to implement the solid radioactive waste
management and transportation programs. The staff responsible for implementing the solid radioactive waste and transportation programs had completely changed during the time period between January 1996 and May 1997, but no reduction in program performance was noted (Section R6).
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-3 A comprehensive audit of the radioactive waste management and transportation
programs was performed. No quality assurance radioactive waste surveillances had been performed in more than 3 years. No department self-assessments of the radioactive waste management and transportation progran.. had been performed (Section R7)..
A noncited violation was identified for the failure to locate air sample and broadleaf
vegetation sample locations in accordance with Technical Requirement Manual Section 3.12.1 (Section R8).
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Benort Details Summarv of Plant Statu.g u
The station operated at 100 percent power during this inspection. No events occurred during this inspection that adversely affected the inspection results.
[V. Plant Support R1 Radiological Protection and Chemistry Controls R 1.1 Solid Radioactive Waste Mananement a.
insoection Scooe (86750)
The inspectors interviewed members of the radiological programs orge,ization and the radiological materials control group and observed or reviewed the following solid radioactive waste management program activities:
Container storage and labeling
Container acccuntability
Radioer sive waste storage areas
Waste stream sampling results and waste characterization documentation
Scaling factors for required isotopes not measured directly
Solid radioactive waste classification
Sluicing of spent resin into a high integrity container
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Quantities of radioactive waste shipped for disposal
Waste minimization program
Annual radioactive effluent and solid radioactive waste reports
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Observations and Findinas The inspectors toured areas where radioactive waste / materials were handled, stored, and processed. In general, containers of radioactive waste and radioactive materials were properly labeled and stored. The inspectors observed that several radiological information labels attached to sealand containers stored outside the low level waste storage facility were faded and difficult to read. When this observation was brought to the licensee's attention, the licensee took prompt action to correct the situation. Overall, the radioactive waste processing and storage areas were well maintained. The licensee war in the process of developing a program to maintain an accurate inventory and accountability of packaged radioactive waste and radioactive materials in storage on site and/or ready for shipment. Housekeeping in the radioactive waste processing and storage areas was goo.
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The licensee used a vendor laboratory for waste stream analysis. Scaling factors were computed to account for isotopes that were not easily detected and for required nongamma emitting nuclides. The licensee's computer program data base was updated with the latest waste stream analysis and scaling factor results.
The licensee used a vendor supplied computer program to classify and characterize radioactive waste for burialin accordance with the requirements of 10 CFR 61.55.
The licensee had identified various radioactive waste streams, which were representative of waste generated. Radioactive Waste System Procedure RWS-0206, "Radwaste Scaling Factors Program," Revision 7, listed dry active waste as one of the waste streams used to meet 10 CFR 61.55 analysis requirements.
l Paragraph 6.4 states that smears for the dry active waste stream sample should be taken from the radwaste compactor ram. In the event the compactor is not l
functional or the sample activity is not sufficient for analysis, then smear samples l
should be taken from the following areas: residual heat removal pump room,
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drywell, containment refueling floor, reactor water cleanup pump room, and turbine building to provide a representative sample for the dry active waste stream.
On August 6,1997, during the review of waste stream sample collections and I
analyses for the generation of appropriate scaling factors for the various waste streams, the inspectors determined that the licensee was not collecting and analWng smear samples as described in Procedure RWS-0206 to determine the isotopic content for the dry active waste stream, instead, the licensee was using the liquid waste stream resin sample and associated scaling factors for the classification and characterization of dry active waste for shipment. 10 CFR 61.55 (a)(8) requires that the source of radioactive waste be identified and sampled, and the concentration of radionuclides determined by direct measurement or by indirect
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of one radionuclide to another that is measured. Although the licensee stated that an evaluation was performed, they were not able to provide documentation that would substantiate that liquid and dry waste had the same scaling factors. The failure to collect smear samples for the dry active waste stream and determine the radionuclide concentration is a violation of 10 CFR S1,55(a)(8)(50 458/9703 01).
The inspectors were not able to determine if any shipments of dry active waste had been incorrectly manifested because of this issue.
Technical Specification 5.4.1 requires that written procedures shall be established, implemented, and maintained covering the. activities as recommended in Appendix A of Regulatory Guide i.33. Section-7.b of Appendix A of Regulatory Guide 1.33 requires procedures for the control of radioactivity related to the solid waste system. Radioactive Waste System Procedure RWS-0206, "Radwaste Scaling Factors Program," Revision 7, paragraph 8.1, states, in part, "Radwaste scaling factors shall be validated at least... btennially for Type A waste." On August 6, 1997, the inspectors determined that between September 1993 and July 1996, scaling factors for Type A waste streams were not validated biennially for 55 gallon
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i drums, spent fuel cleanup resin, condensate resin, and sealand container waste.
~ The failure to validate scaling factors for Type A waste at least biennially is a
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violation of Technical Specification 5.4.1 (50 458/9703 02).
The volume and activity of solid radioactive waste including resins, filters, irradiated components, and dry active waste shipped for disposal during the past 5 years is tabulated below. This data indicates solid radioactive waste shipped,' not buried; therefore, the data does not show any volume reduction due to incineration.
l Resin and Filters Dry Active Waste Total Volume Activity Volume Activity Volume Activity Year (ft')
(Cl)
(ft')
(Ci)
(ft')
(Ci)
1992 7,709.4 682 7,419.8 7.38 15,129.2 689.4 1993 3,810.6 150 1,921.2 1.62 5,731.8 151.6
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1994 3,814.1 398 6,074.3 4.49 9,888.4 402.5 i
1995 3,708.2 308 1,497.4 7,42 5,205.6 315.4 1996 3,196.1 505 953.5 2.31 4,149.6 507.3 Over the past 5 years, the inspectors noted a trend of decreasing total volume and curies of radioactive waste shipped for disposal. The inspectors confirmed, through document reviews and personnel inten*iews, that the licensee had implemented an effective solid radioactive waste reduction program. Since 1992, the total annual volume of solid radioactive waste generated has been reduced by approximately 73 percent.
Baseo on licensee supplied radioactive waste data, the 3 year weighted average of 408 curies shipped during 1994-1996, placed the licensee in the second quartile for
.adioactive waste activity for boiling wate reactors nationally, c.
Conclusions Overall, a good solid radioactive waste management program was implementod. The licensee effectively reduced the volume and radioactivity of solid radioactive waste generated. -_in general, solid radioactive waste was properly classified and characterized for shipment and disposal. However, two violations were identified
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for the failure to collect smear semples for dry active waste and validate scaling f actors for Type A waste biennially.
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i R 1.2 Transoortation of Radioactive Materials and Radioactive Waste a.
Inspection Scone (86750)
The inspectors interviewed radiological materials control group personnel and reviewed the following:
Implementation of revised 49 CFR Parts 100179 and 10 CFR Part 71
Shipping documentation from selected shipments (April 1996 to July 1997)
Certificates of compliance for NRC certified shipping casks
Department of Transportation and NRC regulations and state licenses
Licenses for recipients of radioactive wastes and/or materials
Marking and labeling of packages for shipment
Vehicle placarding and driver instructions
Emergency response information
Radiation surveys of packages and vehicles
Packaging and shipping papers for shipments
Use of system international units
Use of the current A /A values
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Computer program to generate shipping papers
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Observations and Findinas No shipments of radioactive wastes or radioactive materials were made during the week of inspection; therefore, no observations of actual shipment preparation were possible.
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A vendor supplied computer code was used to determine proper radioactive materia!
transportation categories, shipping packages, labeling, and to generate shipping papers. The inspectors verified that the radwaste computer program used the current A and A values for selected isotopes from 49 CFR 173.435.
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The inspectors reviewed shipping papers for selected shipments of radioactive waste and/or materials made from the station after April 1,1996, to determine compliance with the revised Department of Transportation and NRC regulations for shipments. Several shipments required Type B packages. Shipments of dry active waste typically went to a vendor for volume reduction before ultimate waste burial.
The inspectors verified that radioactive waste and radioactive materials shipments complied with 49 CFR Part 172, Subpart C,10 CFR Part 20, Appendix F, 49 CFR 173.433 and 49 CFR 173.435. Shipping papers included radioactive source activity measurements recorded in international system units, as well as, customary units which were required on packaging and shipping documentation after April 1,199.-
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-On August 7,1997, during the review of condition reports the inspectors noted that condition report 97-1034 documented that a mSnifeu datec July 11,1997, for Resin Shipment 97-0035 to NWT Corporation, recorded radionuclide quantities which exceeded the transferee's license requirements. Upon receipt of the shipment and review of the shipment manifest, NWT Corporation notified the licensee that the quantity of radioactivity shown on the manifest exceeded their license requirements. A licensee investigation determined that the isotopic activity data was inputted into the radwaste computer program using the wrong units for the sample analysis results. The radwaste computer was used to generate the shipment manifest. Input of the isotopic activity data using the wrong units caused the calculation of an erroneously high quantity of radioactivity. The licensee corrected the manifest using the correct units. The corrected manifest showed that the actual shipment quantity of radioactivity did not exceed the transfesce's license l'
requirements.
l-10 CFR Part 20, Appendix F Part 1, requires that shipment manifests contain radionuclide identity and quantity and the total radioactivity of the shipment.
The licensee's investigation also revealed that although the shipper initialed the step on the shipment checklist which showed that the quantity of radioactivity shipped did not exceed the transferee's license requirements and to ensure compliance with 10 CFR 30.41(c), the shipper again misinterpreted the radioactivity units. The failure to record correct total quantity of radioactivity on the shipment manifest is a violation of 10 CFR Part 20, Appendix F, Part I (50-458/9703-03).
Radiation survey records indicated that radiation and contamination levels of shipments were within regulatory limits. Emergency telephone numbers included with the shipping papers were current.
The inspectors verified that the licensee maintained current copies of applicable certificates of compliance for NRC approved shipping casks; Department of Transportation, NRC, and the competent state authority regulations, appropriate
.iate licensec. and state transportation permits; and copies of current licenses for recipients of shipments of radioactive wastes and/or materials. This was consistent with the licensee's commitments to inspection and Enforcement Bulletin 7919.
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Conclusions A gcod transportation program for radioactive materials and radioactive waste was -
maintained. Packages were properly prepared for shipment. Current A, and A2 values were being used to characterize shipments in accordance with transportation regulatioris. Generally, Jhipments of radioactive materials were made consistent with the laisst revisions to the Department of Transportation and NRC regulations.
However, a violation was identified for the failure to properly calculate the quantity and total radiosctivity of a radioactive waste shipment.
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R2 Status of Facilities and Equipment
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The inspectors toured the radwaste areas in the station aad determined that the facilities were as described in the updated final safety analysis report.
R4 Staff Knowledge and Performance
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Insoection Scone (86750)
The inspectors interviewed members of the radiological mattrials control group, b.
Observat;ons and Findinas Through interviews and discussions, the inspectors determined that the personnel responsible for conducting the transportation program for radioactive waste and radioactive materials were knowledgeat,le of currently revised transportation regulatory requirements which were effective April 1,1996, c.
Conclusions The radiological materials control section was adequately staffed with properly trained and qualified personnel.
R5 Staff Training and Qualification a.
Inspection Scone (86750)
The inspectors reviewed the periodic training of personnel who were responsible for the preparation and packaging of radioactive waste and radioactive materials for
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shipment.
The inspectors reviewed the following:
Training materials related to 49 CFR Parts 171-179 and 10 CFR Part 71
Training and qualification records of the personnel performing radioactive
waste and radioactive materials shipments b.
Observations and F_indinas The inspectors verified that personnel responsible for the preparation of radioactive waste and radioactive materials shipments had periodic retraining within the previous 2 years and were trained on transportation regulation revisions prior to implementation of the new regulatory requirements effective April 1,1996.
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The inspectors verified that radwaste personnel including health physics specialists and radiation protection technicians were appropriately trained. The health physics specialists demonstrated a thorough icnowledge of the revised transportation regulations.
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Conclusions The training program properly addressed the revisions to the transportation regulations. All personnel participating in the preparation and packaging of radioactive waste and radioactive materials were appropriately trained.
R6 Rediological Protection and Chemistry Organizatioa and Ariministration a.
Ln_socction Scone (86750)
The radiological programs organization and staffing for the solid radioactive waste management and transportation programs for radioactive waste and materials were reviewed, b.
Observations and Findinas Since the last inspection of the solid radioactive waste management program, the organizational alignment for the radioactive waste program changed significantly.
The radiological programs department took complete responsibility for the implementation of the radioactive waste management program. The radioactive materials and radwaste section was created within the radiological programs organi7ation. The inspectors verified that radioactive materials control and radwaste section personnel were responsible for the implementation of the solid radioactive waste management program and transportation of radioactive waste and radioactive materials program. Two health physics specialists assigned to the radioactive materials control and radwaste section were responsible for the preparation of radioactive waste and radioactive materials for shipment. The inspectors determined that the duties and responsibilities for implementing the solid radioactive waste management program and the transportation program for radioactive waste and radioactive materials were being properly implemented.
The organization and staffing of the radiological programs department and radiological materials control and radwaste section were adequate to implement the solid radioactive waste management program and transportation program for radioactive waste and radioactive materials. However, changes to the entire staff directly responsible for the management and implementation of the solid radioactive weste and transportation programs were made between January 1996 and May 1997. These changes included the radwaste supervisor, two health physics specialists, and four radiation protection technicians. The inspectors did not identify any reduction in program performanc.
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Conclusiong The inspectors determined that proper staffing was maintained to implement the sohd radioactive waste management and transportation programs. The licensee's staff responsible for implementing the solid radioactive waste and transportation programs had completely changed during the time period between January 1996 and May 1997. No reduction in program performance was noted.
R7 Quality Assurance in Radiological Protection and Chemistry Activities a.
Insoection Scoce (86750)
The members of the audit team including the technical specialist involved with the performance of the quality assurance audit of the solid radioactive waste management and transportation of radioactive materials programs were interviewed.
The following items were reviewed:
Qualifications of auditors and technical specialist
Quality assurance audit performed since January 1996
Radiological condition reports written since January 1996
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Observations and Findinas Qualifications of the audit team members and the technical specialist, who performed the quality assurance audit, were reviewed. The inspectors noted that the two auditors had a number of years of auditing experience in the radiation protec: ion area but a limited background in radioactive waste management.
RadiWctive waste management courses were provided to enhance the auditors'
knowledge of the radioactive waste management program and current regulatory requirements.
The 1996 quality assurance audit of the radioactive waste management and process control programs was performed using a technical specialist, who had experience in the radioactive waste management program area.
The inspectors reviewed the 1996 audit plan and audit report and determined that the audit was comprehensive and provided a thorough overview of the radioactive waste management and transportation programs. The audit identified numerous deficiencies in the radioactive waste program area. As a result of the audit, six condition reports were written to track the implementation of appropriate corrective actions. Due to the number of deficiencies identified, a quality assurance follow-up evaluation is scheduled for October 1997 to verify effective resolution of the issues identified. An Entergy Operations, Inc., peer ovaluation of the radioactive waste management and transportation programs is also scheduled for September 1997.
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-12 The inspectors noted that one of the 6 condition reports issued contained 27 action items. Since October 1996, due date extensions were requested for 10 action
. items and 8 of the action items still remain open pending completion of corrective actions. The inspectors noted that due to the numerous issues identified during the audit the condition reports were not all closed in a timely manner,
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No quality assurance surveillances of the solid radioactive waste and transportation programs were performed since July 1994.
The radioactive materials control and radwaste section had not performed any department self assessments of the radioactive waste management and transportation programs.
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Conclusions (
A comprehensive audit of the radioactive waste management and transportation programs was performed. A te.,hr;ical specialist knowledgeable in radioactive waste management and transportation requirements was a member of the audit teams.
No quality assurance radioactive waste surveillances had been performed since July 1994 No departmental self-assessments of the radioactive waste management and transportation programs had been performed.
I R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 (Closed) Unresolved item 458/9620 01: Evaluation of Environmental Monitorinn Statioc, Localipns Due To The Recalculated D/O Valugg The unresolved item was based on the review of the results of a licensee's quality assurance audit conducted June 10 21,1996, which identified that the backg;ound (control) environmental air sampler may have not been located in accordance with the Technical Requirements Manual requirements. The licensee's evaluation of the environmental air sampler control location and other environmental monitoring sample locations were documented in Condition Reports 961148 and 961269.
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The licensee evaluated the radiological environmental monitoring program indicator and control sample locations for air sampling, gardens for vegetation sampling, and thermoluminescent dosimeters. The inspectors reviewed the licensee's evaluation and corrective actions implemented as documented in the condition reports.
The licensee's evaluation of the data from three control air sampler locations over the p::::t 7 years rhowed no significant differerices. The continued availability of the historical valid background (control) data from the air sampler location (AGS) in 7achary, Louisiana, was maintained. Beginning January 1997, the control air sampler location (AGS) was renamed AGC (SE) and remained located at the Entergy Seivice Center in Zachary at a distance of 17 kilometers from the River Bend Station.
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-13-The licensee's evaluation of the three indicator air samp'er locations showed that only one air sampler location, AP1 (WNW), met the Technical Requirements Manual requirement of being located in one of the three highest calculated annual average-
- ground level D/O sectors close to the site boundary.= Based on the evaluation,-two -
~ new air sampler locations, AQ1 (NW) and AN1 (W), were established in January 1997 to meet the requirements in tha Technical Requirements Manual. The two historical air sampler locations, AA1 (N) and AR1 (NNW), which were not in one of j
the three highest calculated ground level D/O sectors, will continuo to operate while y
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baseline data for the two new air sampler locations is being collected. After sufficient time to establish baseline data for the two new air sampler locations and-
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to perform a data comparison and evaluation, the air. sampler locations. AA1 (N) and i
AR1 (NNW) will be discontinued.
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. The licensee's evaluation of the vegetation sample locations showed that broadleaf vegetation was grown in two gardens located in two different sectors of highest predicted annual average ground level D/O near the site boundary as required by the Technical Requirements Manual, but not in the highest predicted sector, N (W). A new garden location was established in Sector N (W), and vegetation samples were collected in July 1997. All three gardens will remain in production until baseline data can be collected and evaluated, After completion of the data comparison, the parden located in Sector Q (NW) will be deleted from the environmental monitoring
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The licensee's evaluation of the 40 routine environmental thermoluminescent dosimeter locations required by the Technical Requirements Manual showed that several minor sample location changes were necessary to provide better accessibility and more efficient dosimeter deployment and collection.
The Offsite Dose Calculation Manual was revised in December 1996 to include the changes made resulting from the evaluation of the environmental monitoring program. A description of the reasons for the changes to the environmental monitoring sample locations was included in the Annual Radiological Environmental.
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The failure to locate air sample and broadleaf vegetation sample locations in accordance with the requirements of the Techtscal Requirement Manual is a violation of Technical Requirement Manual Section 3.12.1, However, this failure constituted a violation of minor significance. Therefore, this licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement. Policy (50-458/9703 04).
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V. L4ananement Meetinga l
X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on August 8,1997. The licensee acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT SUPPLEMENTAL INFORMATION I
i PARTIAL LIST OF PERSONS CONTACTED Licensee I
R. Albert, Quality Specialist, Quality Assurance L. Ballard, Supervisor-Ouality, Quality Assurance L. Dautel, Radiation Protection Specialist, Radwaste D. Deal, Supervisor, Radiation Control
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M. Dietrich, Director, Quality Programs l
D. Heath, Supervisor, Radwaste
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T. Hilderath, Outage Manager J. Holmes, Superintendent, Chemistry D. Lorfing, Supervisor Licensing, Nuclear Safety and Regulatory Affairs J. McGhee, Superintendent, Operations D. Myers, Licensing Specialist, Nuclear Safety and Regulatory Affairs J. Schram, Radiation Protection Specialist, Radwaste l
D. Wells, Superintendent, Radiation Control R. Wilson, Coor' inator, Corporate Radwaste J
NRC W. Smith, Senior Resident inspector D. Proulx, Resident inspector INSPECTION PROCEDURE USED IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED AND CLOSED Opened'
50-458/9703-01 VIO Failure to Determine Dry Active Waste Stream Scaling Factors 50 458/9703-02 VIO Failure to Validate Type A Waste Stream Scaling Factors 8iennially 50-458/9703-03 VIO Failure to Correctly Calculate the Quantity of Radioactivity of a Shipment 50-458/9703-04 NCV Evaluation of Environmental Monitoring Station Locations Due To Recalculated D/O Values
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50 458/9620-01 URI Evaluation of Environmental Monitoring Station Locations Due To Recalculated D/O Values-50 458/9703-04 NCV Evaluation of Environmental Monitoring Station Locations Due To Recalculated D/O Values LIST OF DOCUMENTS REVIEWED ORGANIZATION CHART Radiation Programs Organization Chart July 1997
- QUALITY ASSURANCE DOCUMENTS QAD 1, " Organization," Revision 14C QAD 18, " Audits," Revision 12B QAl 2.1, " Audit Process," Revision 15 OAl-2.3, " Performance and Reporting QA Surveillance of Plant Activities," Revision 10 Quality Assurance Audits Gehedules - 1996 and 1997 Quality Assurance Audits Quality Assurance Audit Report 96-10-1-RWPCON, "Radwaste Management and Process Control Programs," December 18,1996 Quality Assurance Surveillance Quality Assurance Surveillance Report 408001, " Radioactive Waste Shipping,"
July 29,' 1994 PROCEDURES RbNP-001, " Control and Use of RBS Procedures," Revision 15
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RBNP 024, " Radiation Protection Plan." Revision 7 RBNP-030, " Initiation and Processing of Condition Reports," Revision 10B RWS-0204, "Radwaste Processing Control Program," Revision 6
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3-RWS-0206,_"Radwaste Scaling Factors Program," Revision 7 RWS 0207, "Radwaste Shipping Procedure," Revision 11 RWS-0304, " Radioactive Waste Handling and Control," Revision 9 RWS-0321, " Operation of the Radweste Shipping Computer Softwers," Revision 2 REPORTS Annual Radioactive Effluent Release Reports 1995 and 1996 MISCELLANEOUS DOCUMENTS j
Summary of Radwaste Condition Reports written since January 1996
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