IR 05000483/1998017

Insp Rept 50-483/98-17 on 980803-07.Violations Noted.Major Areas Inspected:Implementation of Solid Radioactive Waste Mgt & Radioactive Matls Transportation Program

ML20237B898
Person / Time
Site:	Callaway
Issue date:	08/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20237B886	List: IR 05000483/1998017 ML20237B884 ML20237B893
References
50-483-98-17, NUDOCS 9808200061
Download: ML20237B898 (11)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-483 License No.: NPF-30 Report No.: 50-483/98-17 i Licensee: Union Electric Company Facility:

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Callaway Plant Location: Junction Hwy. CC and Hwy. O Fulton, Missouri Dates: August 3-7,1998 Inspector: Michael P. Shannon, Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment : Supplementalinformation

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EXECUTIVE SUMMARY l

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Callaway Plant  !

NRC Inspection Report 50-483/98-17 This announced, routine inspection reviewed the implementation of the solid radioactive waste management and radioactive materials transportation program Plant Support

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Overall, a good solid radioactive waste management program was in place. The licensee's radwaste minimization program was effectively implemented. Since 1994, the total annual volume of solid radioactive waste generated was reduced by approximately 63 percent. Housekeeping in the radwaste building was very good (Section R1.1).

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A violation of 10 CFR 71.111 was identified because dry active waste was stored within 10 feet of a permanent structure contrary to procedural requirements. The procedural requirement was in place to address potential fire protection concerns (Section R1.1).

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A very good transportation program for radioactive waste and materials was maintaine Shipping documentation was organized, easily retrievable, and packages were properly prepared for shipment. Proper emergency telephone numbers were included on shipping manifests (Section R1.2).

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A strong solid radwaste and transportation training program was maintained. The instructor assigned to provide initial and continuing solid radwaste and transportation training to the staff involved in the packaging, storage, and transportation of radioactive waste and materials had an extensive, practical and technical background in the above program areas. Lesson plans were organized, well written, and plant management was appropriately involved in the development and review of the plans (Section RS).

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An effective quality assurance program was in place. The biennial audit, when combined with surveillance reports, provided management with a good assessment of the solid radwaste and transportation programs. The licensee properly assessed and captured recommendations from the department self-assessment. No negative trends were identified during the review of solid radwaste and transportation suggestion occurrence solution reports (Section R7).

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-3-Report Details Summarv of Plant Status The station operated at 100 percent power during this inspectio IV. Plant Support R1 Radiological Protection and Chemistry Controls R Implementation of the Solid Radioactive Waste Proaram inspection Scoce (86750)

The inspector interviewed licensee personnel and reviewed the following:

. Waste stream sampling results and waste characterization documentation

. Scaling factors for required isotopes not measured directly

. Solid radwaste disposal totals

- Waste minimization program

. Waste shipment manifests

. Waste storage and container accountability

. Annual radioactive effluent and solid radioactive waste reports Observations and Findinas The inspector verified that waste stream samples were taken as required and analyzed to meet 10 CFR Part 61 requirements for waste classification and characterization. The licensee had identified various radioactive waste streams. The inspector determined that these waste streams were representative of waste generated and were properly analyzed by a contractor laboratory. Additionally, the inspector verified that the results were used to updste the software for selecting the proper containers for radioactive material shipments and for characterizing and classifying waste shipment Classification of waste was performed with a computer code used in the nuclear industry. Scaling factors for difficult to measure nuclides ir the waste streams were determined and updated as needed in the radwaste computer code data base. A review of selected examples of radioactive waste packaged for burial determined that the waste was properly classified and characterize A review of the annual radioactive effluent release reports for 1996 and 1997 revealed that the reports contained the required solid radioactive waste dat Dry active waste was shipped to an off-site vendor for volume reduction and subsequent burial. A summary of the volume and activity of solid radioactive waste including resins, irradiated co.nponents, and dry active waste shipped for disposal during the past 4 years is tabulated below:

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-4-Waste Burial Resin and Dry irradiated Year Number of Filters Compressible Components Total shipments volume Activity Volume Activity Volume Activity Volume Activity (m3) (Cl) (m3) (Cl) (m3) (Cl) (m3) (Cl)

1994 23 2 .1 7.64 .06 7 __

1995 13 1 .1 0.09 0 0 1 .6 79 4 .58 0 0 5 .3 140 1 .91 0 0 2 Over the past 4 years, the inspector noted a decreasing trend of both volume and curies of radioactive waste shipped for disposal. From discussions with licensee personnel, review of Procedure APA ZZ-01010," Radioactive Waste Management Program,"

Revision 9, and field observations, the inspector determined that the licensee's radwaste minimization program was effectively implemented. Since 1994, the total annual volume of solid radioactive waste generated was reduced by approximately 63 percen The inspector determined that station management was properly involved in establishing the 1998 radioactive waste goal of 6000 cubic feet, and concluded that the goal was challenging in light of the fact that 1998 is an outage year. The inspector noted that for 1 the first 6 months of 1998 dry active waste generation was approximately 2600 cubic '

feet. The inspector commented that it was likely that the licensee could meet its stretch goal of 5000 cubic feet. The licensee acknowledged the inspector's comment.

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The inspector toured areas where radioactive waste / materials were handled, stored, and processed. Housekeeping in these areas was very good. In general, containers of radioactive waste and materials were properly labeled and stored. However, on

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August 3,1998, the inspector noted a number of posting issues in the south radwaste yard; such as, faded radiological postings and labeis on containers of radwaste. When these observations were bought to the licensee's attention, the items were corrected in a timely manne CFR 71.111 requires procedures for the packaging of radioactive waste and materials. Section 2.4.1 of Procedure RTN-HC-00900," Packaging Radwaste in LSA Boxes," Revision 8, states that dry active waste is not to be stored within 10 feet of any permanent structure. From a review of Design input Report RFR 13775-A dated September 27,1993, the inspector noted that a fire protection review required that a 10-foot minimum distance be maintained between any pile of processed and unprocessed dry active waste and any permanent structur The inspector performed an inventory of selected waste containers located in the low level storage area of the radwaste building and noted no problems with the inventor l Containers were properly labeled in accordance with the requirements of 10 CFR 20.1904 and were maintained in good physical condition. However, on August 4,1998, the inspector noted three containers of dry active waste which were I ,

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! stored within 10 feet of a permanent structure. From a review of radiological survey data, the inspector determined that this material was stored in the area at least 4 months earlier. The licensee documented this issue in Suggestion Occurrence Solution Report 98-3153. The dry active waste was moved to an appropriate location the following day. Corrective actions documented in Suggestion Occurrence Solution Report 98-3153 to prevent a similar occurrence were: (1) place signs along the outside wall of the south yard radwaste building walls stating,"Do Not Store Dry Active

! Waste Within 10 Feet of the RW Building"; (2) E-mail was sent to all radwaste environmental personnel reminding them of the procedural requirement; (3) Work Order W199658 was written to paint hash marks on the concrete to demarcate the storage spacing requirement; and (4) training has been requested to include this event in the next radwaste, health physics operations, and radcon helper continuing training clas The failure to follow the requirements of the above procedure is identified as a Violation of 10 CFR 71.111 (50-483/9817-01).

The inspector reviewed the licensee's immediate and proposed long-term corrective actions per1aining to this event and determined that, if implemented, they will likely prevent a similar occurrence. Therefore, the NRC has determined that no response to this violation is required, unless the corrective action described above does not accurately reflect your corrective actions or position. The implementation of the corrective actions will be reviewed during a future NRC inspectio Conclusions Overall, a good solid radioactive waste management program was in place. The I licensee's radwaste minimization program was effectively implemented. Since 1994, the total annual volume of solid radioactive waste generated was reduced by approximately 63 percent. Solid radioactive waste was properly classified and characterized for shipment and disposal. A violat:on of 10 CFR 71.111 was identified because dry active waste was stored within 10 feet of a permanent structure contrary to procedural requirements. The procedural requirement was in place to address potential fire l protection concerns. Housekeeping in the radwaste building was very goo R1.2 Transportation of Radioactive Materials and Radioactive Waste Inspection Scope (86750)

The inspector interviewed licensee personnel and selected examples of the following:

. Radiation and contamination surveys of packages and vehicles

! . Shipping paper documentation

. Package marking and labeling

. Vehicle placarding

< . Notifications to state agencies 4 f

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Emergency response information l

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6-b. Observations and Findinas No shipments of radioactive waste or materials were made during the week of the inspection; therefore, no observations of actual shipments were possibl An effective file system was maintained. The inspector verified that the licensee maintained current copies of the consignees' radioactive material licenses on fil Current copies of both Department of Transportation (DOT) and NRC regulations were l maintained. Certificates of Compliance for routinely used shipping casks were verifie The inspector noted no problems with the records reviewe A vendor supplied computer program was used to determine proper radioactive material transportation categories, shipping package labeling, and the generation of shipping paper The inspector reviewed selected shipping records of radioactive waste and material shipments to determine compliance with DOT and NRC requirements. The inspector concluded that they contained the information required by 49 CFR Part 72, Subpart In addition to this information, radioactive waste shipment documentation included manifests that conformed to the requirements of 10 CFR Part 20, Appendixes F and G; 49 CFR 173.433; and 49 CFR 173.435. Shipping documents included radioactive activity measurements recorded in international system units, as well as, customary units. The inspector verified that proper emergency telephone numbers were included with the shipping papers. The licensee utilized the operations control room to provide emergency response informatio Radiation survey records reviewed indicated that radiation and contamination levels of shipments were within regulatory limit c. Conclusions A very good transportation program for radioactive waste and materials was maintaine Shipping documentation was organized, easily retrievable, and packages were properly prepared for shipment. Proper emergency telephone numbers were included on shipping manifests.

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R2 Status of Radiation Protection and chemistry Facilities and Equipment There were no major changes to the program or the facilities since the last inspection in August 1996. There have been some personnel changes due to the staff attending extended training; however, none of these changes appeared to reduce the

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effectiveness of the solid radwaste and transportation programs. Overall, the inspector i

determined that a proper organization and staff were maintained to effectively implement the solid radwaste and transportation program I

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-7 R5 Staff Training and Qualification a. Inspection Scope (86750)

Personnel involved with the solid radioactive waste management and transportation of radioactive materials training programs were interviewed. The following items were reviewed:

. Instructor qualifications

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Continuing training program

. Training materials related to 10 CFR Part 71 and 49 CFR Parts 171-179

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Management oversight of the training program b. Observations and Findinas The inspector reviewed the qualifications of the instructor assigned to provide initial and continuing solid radwaste and transportation training to the staff involved in the packaging, storage, and transportation of radioactive waste and materials. The inspector determined that the instructor had an extensive practical and technical background in the above program areas. Additionally, this individual was registered by the National Registry of Radiation Protection Technologist A review of selected initial and continuing solid radwaste and transportation lesson plans revealed that plant management was appropriately involved in the development and review of these plans. The inspector determined that the plans were organized, well written, and site and industry lessons learned were included in the training materia A review of the training schedule revealed that training was provided in accordance with the requirements of 49 CFR Part 17 c. Conclusions A strong solid radwaste and transportation training program was maintained. The instructor assigned to provide initial and continuing solid radwaste and transportation training to the staff involved in the packaging, storage, and transportation of radioactive waste and materials had an extensive, practical, and technical background in the above program areas. Lesson plans were organized, well written, and plant management was appropriately involved in the development and review of the plans.

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8-R7 Quality Assurance in Radiation Protection and chemistry Activities a. Insoection Scope (86750)

The inspector interviewed licensee personnel and reviewed the following:

. Auditor qualifications

. Quality assurance audits and checklists

- Quality assurance surveillanc . Department self-assessments

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Suggestion Occurrence Solution reports b. Observations and findinas Audits and Surveillance The inspector reviewed the qualifications of the load auditor responsible for the oversight of the solid radwaste and transportation programs and determined that this individual was propeny trained to assess the programs. The inspector noted that the ,

auditor attended the appropriate initial solid radwaste and transportation training courses; however, he did not normally attend continuing training for these program The inspector commented that because of the complexity of the transportation regulations the licensee might want to consider having this individual attend the l appropriate continuing training courses to maintain and/or improve his knowledge of the solid radwasie and transportation program areas. The licensee acknowledged the  !

inspector's commen l l l

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One audit (AP97-003) of the radwaste program was performed since August 1996. This biennial audit was a combined effluent / solid radwaste audit with the primary focus on the effluent program. The solid radwaste and transportation portion of this audit covered the process control program and the effectiveness of corrective actions. Checklists used for the audit provided assurance that program areas were properly reviewe Three issues were identified during the audit. All the issues were properly documented and tracked in the station's suggestion occurrence solution reporting syste Eight quality assurance department surveillance reports pertaining to the solid radwaste and transportation programs were written since August 1996. The inspector determined that the surveillance were well written and properly assessed the areas reviewed. In  !

general, these surveillance were intrusive and thorough, providing management with a (

i good assessment of the solid radwaste and transportation program areas reviewe The inspector determined that when the audited areas were combined with the surveillance reports, they provided management with a good assessment of the solid radwaste and transportation program A review of the quality assurance planning guide for the radioactive waste program revealed that it covered the appropriate areas to properly assess the solid radioactive waste and transportation programs, t

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No problems were identified during the review of the audit (08.03.YAEMA.98.1)

pertaining to the vendor who performed 10 CFR Part 61 waste stream analysi Department Self-Assessments One department self-assessment (AP97-016) was performed between September 15 and 17,1997. The self-assessment reviewed the station's minimization of the dry active waste program. The inspector noted that a technical specialist from another utility was used during this assessment. The inspector determined that the self-assessment provided management with a good assessment of the station's waste minimization program. The self-asseasment identified a number of recommendations for improvement. The licensee properly assessed and captured these recommendations in the station's suggestion occurrence solution reporting system. The inspector noted that 1 more than 50 percent of these recommendations had been implemented as of August 6, i 199 l Suaaestion Occurrence Solution Reports l

The inspector reviewed selected solid radwaste and transportation suggestion l l

occurrence solution reports written since August 1996 and noted that the licensee identified issues at the proper threshold. The review also identified that, in general, i response timeliness was appropriate and corrective actions appeared to be effective to correct the identified issues. The inspector noted no negative trends during the revie l c. Conclusions An effective quality assurance program was in place. The biennial audit, when combined with surveillance reports, provided management with a good assessment of the solid radwaste and transportation programs. The licensee properly assessed and captured recommendations from the department self assessment. No negative trends were identified during the review of solid radwaste and transportation suggestion occurrence solution report R8 Miscellaneous Radiation Protection and chemistry issues No problems were noted during the review of the radioactive effluent monitor calibration and alarm set point program. From a random selection of liquid batch release permits, the inspector verified that alarm set points were properly calculated using the formulas found in the Offsite Dose Calculation Manua V. Manaaement Meetinas l X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on August 7,1998. The licensee acknowledged the findings presented. No proprietary information was identifie j

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A1TACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee G. Randolph, Vice President and Chief Nuclear Officer R. Affolter, Plant Manager T. Arms, Radiation / Chemistry Supervisor G. Clemens, Radiation / Chemistry Technician J. Cruckshank, Radiation / Chemistry Supervisor G. Dungan, Radiation / Chemistry Helper C. Emerson, Radiation / Chemistry Supervisor F. Forck, Acting Senior Engineer, Quality Assurance G. Hamilton, Supervisor Engineer, Quality Assurance J. Hurla, Radiation /Chemistrv Supervisor J. Kovar, Engineer, Quality Assurance J. Laux, Manager, Quality Assurance R. Miller, Radwaste/ Environmental Supervisor R. Moore, Sertior Training Supervisor J. Otten, Radiation / Chemistry Technician M. Reidmeyer, Engineer /NRC Interface, Quality Assurance NRC D Passehl, Senior Resident inspector INSPECTION PROCEDURES USED 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED. CLOSED. AND DISCUSSED Ooened l

50-483/9817-01 VIO Failure to properly store dry active wast Closed None l

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2-LIST OF DOCUMENTS REVIEWED Quality Assurance Audit . Report AP97-003 Quality Assurance Vendor Audit 08.03.YAEM A.9 Quality Assurance Surveillance SP96-060 Quality Assurance Surveillance SP96-076 Quality Assurance Surveillance SP96-093

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Quality Assurance Surveillance SP96-094 Quality Assurance Surveillance SP97-032 Quality Assurance Surveillance SP98-015 Quality Assurance Surveillance SP98-063

- Quality Assurance Surveillance SP98-079 Self-Assessment AP97-016 Annual Radioactive Effluent Release Reports for 1996 and 1997 (Solid Radwaste portions only)

Offsite Dose Calculation Manual, Dated March 6,1998 Selected Solid Radwaste and Transportation Suggestion Occurrence Solution Reports written since August 1996 i

Procedures APA ZZ-00015,"Conouct of Operations-Chemistry and Radwaste." Revision 14 APA-ZZ-01010, "Callaway Plant Radioactive Waste Management Program," Revision 9 APA-ZZ-01011. " Process Control Program Manual," Revision 5 GDP-ZZ-01810 " Quality Assurance Assessment Coverage," Revision 18 RTN-HC-00900, " Packaging Radwaste in LSA Boxes," Revision 8 RTN-HC-01000," Storage and Handling of Radwaste," Revision 11 l RTN-HC-01100," Shipment of Radioactive Materials," Revision 10 RTS-HC-01130,"10 CFR 61 Sampling Program," Revision 6 RTS-HC-01160," Shipment of Radioactive Wastes

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