IR 05000528/1997026
| ML17313A155 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/24/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17313A154 | List: |
| References | |
| 50-528-97-26, 50-529-97-26, 50-530-97-26, NUDOCS 9712310092 | |
| Download: ML17313A155 (28) | |
Text
E CLOSUR U.S. NUCLEAR REGULATORYCOMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved By:
Attachment:
50-528; 50-529; 50-530 NPF-41; NPF-51; NPF-74 50-528/97-26; 50-529/97-26; 50-530/97-26 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona December 8-12, 1997 Gilbert L. Guerra, Jr., Radiation Specialist Plant Support Branch Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Supplemental Information 97i23i0092 97i224 PDR ADQCK 05000528
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Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report 50-528/97-26; 50-529/97-26; 50-530/97-26 This announced, routine inspection reviewed the implementation of the solid, radioactive waste management and the radioactive materials transportation programs.
Training, quality assurance oversight, and procedural guidance were also reviewed.
lan A very good solid radioactive waste management program was implemented.
The generation of dry active wastes had been reduced (Section R1.1).
A very good transportation program for radioactive materials and radioactive waste was maintained.
The licensee satisfactorily implemented the revisions of 49 CFR and 10 CFR Part 71. Shipments of radioactive materials were made consistent with the latest revisions to the Department of Transportation and NRC regulations (Section R1.2).
Excellent facilities were maintained for the storage and management of solid radioactive wastes and transportation activities (Section R2).
Proper procedures for handling, processing, and shipping of radioactive waste/materials were maintained (Section R3).
Training provided to workers adequately addressed the revisions in the transportation regulations.
Personnel involved in the transfer, packaging, and transport of radioactive materials and wastes were properly trained and qualified (Section R5).
A proper organization and staff were maintained which effectively implemented the radioactive waste management and transportation of radioactive materials programs (Section R6).
An effective audit/self-assessment program was maintained.
Strong management oversight was maintained for the solid radioactive waste management and transportation programs (Section R7).
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Palo Verde Units 1, 2, and 3, operated at full power during this inspection.
No events occurred during this inspection that adversely affected the inspection results.
R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Ii i
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The inspector interviewed members of the radioactive materials control group and
'observed or reviewed the following solid radioactive waste management program activities:
Waste stream sampling results and waste characterization documentation Scaling factors for required isotopes not measured directly Solid radioactive waste classification Quantities of radioactive waste shipped for disposal Waste minimization program Solid radioactive waste reports b.
rv ions nd Findi s
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.
Five waste streams were identified for each unit that consisted of dry active waste, resin, filters, concentrates, and other. Some of the waste streams were further broken down into sub-waste streams.
The waste..tream sam~les were analyzed by a contractor laboratory.
Classification of waste was performed with a computer code commonly used in the nuclear industry. Scaling factors determined from waste stream sample analyses were entered into the computer code data base.
The computer code data base was routinely updated with the latest waste stream sampling results.
No problems related to waste stream sampling or waste classification were identified. The inspector noted that the radwaste computer code was updated with the most current revisions of the vendor software, after acceptance by the licensee.
The inspector noted that Palo Verde had reduced the amount of solid radwaste generated; especially, dry active wastes.
This was done, in part, by enhancing radworker awareness in minimizing radioactive waste when performing their assigned tasks and maintaining the amount of contaminated area to a minimu j1 Ij t
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Radwaste generation, tracked by the licensee as pounds generated with no segregation, processing, or volume reduction, has steadily been reduced each year.
Good performance was noted in the licensee's dry active waste minimization program.
The following table of licensee data shows a very good decline in dry active waste generated.
Solid Waste Reduction Results (Pounds of DAW)
1992 1993 1994 286,886 228,139 165,304 1995 1996 162,154 89,377 1997 68,000 (estimated)
Annual Radioactive ENuent Release Reports contained the required solid radioactive waste data.
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 components, and dry active waste shipped for disposal during the last six years is tabulated below.
Year 1992 1993 1994 1995 1996 1997 Number Of Shipments 154 145
" 144
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Volume (m')
425 229 40y y 218" 421 606 132 Total Activity (Ci)
1170 644 416 0.965 16.6 583 c.
Conclusions A very good solid radioactive waste management program was implemented.
The generation of dry active wastes had been reduced.
Waste stream sampling met regulatory requirements.
Solid radioactive waste was properly classified and characterized for shipment and disposa C l
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Ma erials and R i
c iv W In ion
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n The inspector interviewed radioactive materials control personnel and reviewed the following:
Implementation of revised 49 CFR Parts 100-179 and 10 CFR Part 71 Shipping documentation from selected shipments Certificates of compliance for NRC certified shipping casks Copies of current Department of Transportation and NRC regulations Copies of current licenses for recipients of radioactive wastes/materials Use of a vendor supplied computer program to generate shipping papers Packaging and shipping papers Marking and labeling of packages for shipment Vehicle placarding and driver instructions Emergency response information Radiation surveys of packages and vehicles Use of system international (Sl) units Use of the current A,/A, values for isotopes Observa ions n
Find'n The inspector observed the final preparations for a contaminated oil shipment.
This included final radiation surveys of packages and the vehicle and shipping documentation preparation.
The inspector noted that the vehicle was properly placarded and that the driver was given proper instructions, the required shipping documentation, and emergency response information. The shipment preparation activities were conducted well.
An effective file system was maintained.
Selected shipping records showed that the licensee had made shipments of both radioactive materials and radioactive waste.
The inspector noted that shipments using the new category for surface contaminated objects had been performed.
Instructions for surface coritaminated object packaging and shipping were included in licensee procedures.
The inspector noted no problems in the records reviewed.
Certificates of Compliance for routinely used shipping casks were verified. State shipping permits were reviewed.
The inspector reviewed selected shipment consignees and verified the licensee maintained current copies of the consignees radioactive material licenses on file.
A vendor supplied computer code was used to determine proper radioactive material trans'portation categories, shipping packages, labeling, and shipping paper information.
The inspector reviewed the table of A, and A, values used by the program and compared selected radionuclide'values to those provided in the regulations.
The values compared
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-6-were determined to be correct.
The licensee did not utilize the "95 percent rule" to delist radionuclides on shipping papers, preferring to list all radionuclides.
Shipping papers for radioactive materials shipments contained the information required by 49 CFR 172, Subpart C.
In addition to this information, radioactive waste shipment documentation included manifests that conformed to the requirements of 10 CFR Part 20, Appendix F and 49 CFR 173.433.
Shipping documents included radioactive activity measurements recorded in international system units as well as customary units.
The licensee satisfactorily implemented the revisions of 49 CFR and 10 CFR Part 71.
Emergency telephone numbers were included with the shipping papers.
The licensee utilized an offsite facilityto provide emergency response information. The licensee's practice was to fax information on shipment contents to this facilitywhenever shipments were performed.
Radiation survey records indicated that radiation and contamination levels of shipments were within regulatory limits.
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A very good transportation program for radioactive materials and radioactive waste was maintained.
The licensee satisfactorily implemented the revisions of 49 CFR and 10 CFR Part 71. Packages were properly prepared for shipment.
Proper Q and A, values were used to characterize shipments in accordance with transportation regulations.
Shipments of radioactive materials were in agreement with the latest revisions to the Department of Transportation and NRC regulations.
R2 Status of Facilities and Equipment ci The inspector toured the radwaste buildings, the dry active waste processing and storage facility, and the low-level radioactive material storage facility and observed the following solid radioactive waste management. program activities:
Container storage and labeling Container accountability Pre-job briefing b.
Findi s
se ions An excellent low level radioactive material storage facilitywas utilized. The design and ALARAdose saving initiatives, such as cameras, remote radiation survey instrumentation, and remotely operated cranes and grapples of the facilitywere excellent.
The licensee was able to move high dose'rate waste containers with minimal personnel exposur tt
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-7-The inspector attended a pre-job briefing for the transfer of a high integrity container loaded with filters to a storage cell in the low-level radioactive material storage facility.
The briefing was conducted well. Activities and assignments of personnel involved in the job were appropriately discussed, including radiation surveys, communication, and equipment operation including stop work authority.
Storage areas were properly posted and controlled.
Containers were properly labeled and marked.
Housekeeping in the radwaste buildings, the dry active waste processing and storage facility, and low level radioactive material storage facilitywas very good.
The licensee utilized a bar coding system for radwaste container accountability. The bar code system was effective in managing the radwaste inventory. The inventory conducted monthly was efficiently performed with this tool with minimal exposure to personnel involved. The inspector concluded that the licensee could account for all of the radwaste inventory.
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Qgnr~lu ii~n Excellent facilities were maintained for the storage and management of solid radioactive wastes and transportation activities. An effective inventory system was utilized.
R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Tran ion P a.
Ins ction Sco e
I 2 1 /133 and 86750 The inspector reviewed various procedures used to implement the waste stream sampling and analyses and transportation programs; and to verify compliance with the revised Department of Transportation regulations.
The inspector also reviewed the following:
Changes made to procedures for the processing, packaging, and shipment of low specific activity material and surface contaminated objects Use of system international units Observa ions and Findin s The inspector noted that procedures were revised to incorporate changes made to regulations in April 1996. The inspector veriTied that procedures incorporated the recent transportation regulation changes including; new requirements for the transportation of low specific activity materials and surface contaminated objects, and the use of the international system of units on radioactive materials shipping documentation.
Changes to the regulations were appropriately addressed in the radwaste program implementing procedures and current regulations were reference Guidance was provided in the procedures for radioactive waste stream sampling, vendor laboratory analysis, updating the computer code data with new waste stream sample analysis results, and scaling factor generation used to correlate nuclides that were difficultto measure with nuclides that were easy to measure.
Checklists were utilized to provided guidance for the preparation of shipments.
The licensee incorporated the use of the international system of units into the radioactive material shipping documents.
Conclusions Proper procedures for handling, processing, and shipping of radioactive waste/materials were niaintained.
The procedure for shipping low specific activity materials and surface contaminated objects was consistent with regulatory requirements.
R4 Staff Knowledge and Performance The inspector interviewed members of the radioactive material control group of the radiation protection department involved in radioactive waste and transportation activities. Personnel responsible for conducting the transportation program for radioactive waste and radioactive materials were knowledgeable of currently revised transportation regulations that were effective April 1, 1996, and April 1, 1997.
Radwaste staff had an excellent knowledge of the transportation regulations.
Technical specialists were also knowledgeable of the transportation software utilization constraints.
The inspector determined that the radiation protection department was adequately staffed with knowledgeable and experienced personnel.
R5 Staff Training and Qualification in Radiological Protection and Chemistry R5.1 Trainin and u lifica ion of d
e Per o el Ins ec ion Sco e
675 and Tl 515/133 The inspector reviewed the training of personnel who were responsible for the preparation and packaging of radioactive waste and radioactive materials for shipment.
The inspector reviewed the following:
Training materials related to 49 CFR Parts 171-179 and 10 CFR Part 71 Training and qualification records Retraining requirements b.
Observations and Findin s The inspector verified that radioactive material control personnel were trained on the revised regulations prior to the implementation date of April 1, 1996, and that the materials for the required training classes for qualification have been update Training records and qualification cards revealed that all radwaste personnel were trained and qualified in accordance with regulatory requirements and station procedures.
A periodic retraining program was conducted in accordance with commitments made in response to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial." No changes were made to this commitment.
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~Cn iusi ns Training provided to workers adequately addressed the revisions in the transportation regulations.
Personnel involved in the transfer, packaging, and transport of radioactive materials and wastes were properly trained and qualified.
R6 Radiological Protection and Chemistry Organization and Administration a.
In i n co e 84750 The organization and staffing for the implementation of the solid radioactive waste management and the transportation programs were reviewed.
b rv in The organization and staffing related to radioactive waste management and transportation of radioactive materials was appropriate.
Changes were made with the addition of another section leader.
With the addition of a new section leader, duties within the radioactive materials control group were divided. The technical staff experienced little change and no reduction.
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isonclusions A proper organization and staff were maintained which effectively implemented the radioactive waste management and transportation of radioactive materials programs.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Solid Radwas e and Trans ortation Pro ram Assessmen s
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In ction Sco 86750 The inspector reviewed audits, evaluations, and self-assessments to evaluate the licensee's effectiveness at identifying and correcting problems.
The review also included the following:
Qualifications and resumes of auditors and technical specialists Radiological condition reports
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i di Nuclear assurance plant support Audit 97-016 of radwaste activities was conducted August 7-22, 1997. An audit of this area is conducted every 24 months in accordance with Technical Specification requirements.
The audit team included off-site technical specialists.
The inspector determined that the audit was comprehensive in its review of solid radioactive waste management and transportation activities.
Seven nuclear assurance evaluation reports pertaining to the area of inspection were conducted in 1997. The reports were based on observations of activities in progress or existing plant conditions.
Frequent evaluations were conducted that covered diverse areas.
The evaluation reports were effective in providing feedback to radwaste management on program effectiveness.
Also, radiation protection department self assessments were performed on monthly, quarterly, and annual frequencies.
The self-assessments were performed over a wide range of areas within the program.
The inspector determined that this program was a good enhancement to ensure that the required shipping documentation was prepared for all shipments of radioactive material or waste.
The effort expended on quality assurance by the licensee was considered a program strength.
Audit findings were tracked as part of the condition reporting system.
The inspector noted that the radiation protection organization responded properly to the findings. Other selected condition reports involving radioactive waste activities were reviewed.
No adverse trends were noted. Appropriate corrective actions were taken and timely closure was noted.
Auditor qualifications were reviewed, including resumes of technical specialists.
The qualifications and experience of auditors were appropriate.
The inspector determined that the experience of the lead auditor for radwaste activities was very good.
However, the inspector noted that the auditor had not received formal training on the revised transportation regulations.
There is no regulatory requirement to provide this specific training to auditors.
Qi~i,~in An excellent quality assurance program was maintained.
Through the use of a thorough audit, good evaluation reports, and periodic self-assessments, the licensee implemented a strong management oversight program for the solid radioactive waste management and transportation programs.
Technical specialists knowledgeable in radioactive waste management and transportation requirements were members of the audit teams.
Condition reports related to radioactive waste activities were closed in a timely manne il
-11-RS Miscellaneous Radiological Protection and Chemistry Issues R81 I
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I'n May 29, 1996, the licensee identified that between August 30, 1995, and December 22, 1995, the post-accident sampling system was inoperable for 75 days exceeding the 7-day limitfor inoperability. This was identified as a violation of Technical Specification 3.3.3.1.
During the monthly performance of surveillance tests, miscalculations of the amount of dissolved hydrogen within the reactor coolant system indicated that the criteria had been met for test acceptance.
However, had the calculations been performed correctly the surveillance test would have failed. Hence, the licensee declared the post-accident sampling system inoperable.
Monthly surveillance tests were performed on August 30, and September 27, 1995. An 18-month surveillance was performed on November 25, 1995.
In each of the three surveillance tests the hydrogen gas calculations were performed erroneously.
The December 22, 1995, surveillance test was performed satisfactorily. The calculations were in error because the wrong pressure reading was used in the calculations.
The licensee's investigation cited causal factors for this error as the result of inattention to detail and poor procedural communication (surveillance test calculational worksheet).
Corrective actions have been implemented to revise the appropriate portions of the surveillance test calculational worksheet and provide department training on performing post accident sampling system calculations.
This nonrepetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
(50-530/9726-01)
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X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee's management at an exit meeting on December 12, 1997. The licensee acknowledged the findings presented.
No proprietary information was identifie ti
SUPPLEMEN C
~ic ~e R. Bouquot, Section Leader, Nuclear Assurance T. Dickinson, Senior Technician, RMC D. Elkinton, Nuclear Assurance - Plant Support M. Fladager, Radiation Protection Section Leader, RMC P. Guay, Department Leader, Chemistry Operations R. Henry, Site Representative, Salt River Project V. Huntsman, Department Leader, Radiation Protection D. Kanitz, Senior Engineer, Nuclear Regulatory Affairs A. Krainik, Department Leader, Nuclear Regulatory Affairs D. Larkin, Senior Engineer, Nuclear Regulatory Affairs D. Leith, Senior Technical Advisor, Radiation Protection D. Marks, Section Leader, Nuclear Regulatory Affairs S. Sawtschenko, RMC Section Leader, Radiation Protection J. Scott, Director, Site Chemistry J. Steward, Department Leader, Radiation Protection
~NR None INSPECTION PROCEDU ES USED TI 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 86750
~Oened 530/9726-01 Closed 96-001 530/9726-01 Discussed None Solid Waste Management and Transportation of Radioactive Waste i ~
q g~Q i'TEMS OPE ED C OSED A D DISCUSSED NCV Inoperable Post-Accident Sampling System LER Inaccurate Gas Calculations for the Post Accident Sampling System NCV Inoperable Post-Accident Sampling System
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VIEWED EKQQMi~r 76DP-ORP01 Radioactive Material Control Program Overview, Revision 0 76DP-ORP02 Radioactive Waste Minimization Program Overview, Revision 0 76DP-ORP03 Radwaste Process Control Program, Revision 0 76DP-ORP04 Receipt, Storage, and Shipment of Radioactive Material, Revision
76DP-ORP05 Radwaste Management and Volume Reduction Activities, Revision 0 76DP-ORW06 Packaging, Marking and Labeling of Radioactive Material, Revision 5, 4/1/96 76DP-ORW07 Shipping of Radioactive Material, Revision 10, 4/5/96 76DP-ORW09 Shipping of Radioactive Waste, Revision 5, 4/3/96 76RP-ORW01 Operation of RMC Equipment and Facilities, Revision
76RP-ORW03 Waste Stream Sampling and Database Maintenance, Revision 0 76RP-ORW04 Receipt of Radioactive Material, Revision 0 76RP-ORW05 Packaging and Classification of Radioactive Waste, Revision 0, 12/5/97 76RP-ORN/06 Packaging of Radioactive Material, Revision 0, 12/5/97 76RP-ORW07 Shipping of Radioactive Material, Revision 0, 12/5/97 76RP-ORN/09 Transfer and Storage of Radioactive Filters, Revision 0 76DP-ORW06 Packaging, Marking and Labeling of Radioactive Material, Revision 5 15DP-OTR45 Radiation protection Training Program Description, Revision 12
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en Audit 97-016 - Radwaste 9/25/97 Evaluation Reports:
97-0201, 97-0202, 97-0289, 97-0341, 97-0356, 97-0446, 97-0527 Self Assessments:
Quarterly:
Radioactive Shipping Review 9/26/97 Radioactive Shipping Review 6/26/97 Processing, Packaging, Storage, and Transportation of Radioactive Material 11/8/96 Radwaste Quarterly 5/31/96 Radioactive Shipment Review 3/29/96 Monthly:
10/30/97, 9/26/97, 8/12/97, 7/18/97, 6/20/97, 5/15/97, 4/18/97, 3/6/97, 2/28/97, 1/28/97 Annual Radioactive Material Control Self Assessment 11/96 Condition Reports: 1-7-0336, 9-7-1 082 Training and Qualification Records
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