ML20058G854

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Insp Repts 50-313/90-32 & 50-368/90-32 on 900924-28.Major Areas Inspected:Select Portions of Occupational Radiation Protection,Transportation & Solid Radwaste Programs
ML20058G854
Person / Time
Site: Arkansas Nuclear  
Issue date: 11/05/1990
From: Baer R, Murray B, Ricketson L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058G851 List:
References
50-313-90-32, 50-368-90-32, NUDOCS 9011140076
Download: ML20058G854 (13)


See also: IR 05000313/1990032

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION-

REGION IV

NRC Inspection Report: 50-313/90-32.

' Operating Licenses: ORP-51-

50-368/90-32

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NP F-6

Dockets: 50-313

50-368

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Licensee: Entergy Operations, Inc. (E01)

P.O. Box 551

Little Rock, Arkansas 72203

Facility Name: Arkansas Nuclear One (ANO) Units 1 and 2

Inspection At: AND Site, Russellville, Arkansas

Inspection Conducted: September 24-28, 1990

Inspectors:

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R.'E. Baer, Senior Reactor Health Physicist

Date.

Radiological Protection-and Emergency

Preparedness Section

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'C T. RJcKe 'od Senior Radiation. Specialist

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Radio ogi

Protection and Emergency

Pre _

ness Section

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Approved:

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B'. Rur~ ray, ChT6f, Radiological Protection

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andEmergencyPrep3ednessSection

Inspection Summary

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Inspection Conducted September 24-28, 1990 (Report 50-313/90-32: 50-368/90-32)

Areas Inspected: Routine, announced inspection of select portions of the

occupational radiation protection, transportation, and solid radioactive waste

programs.

Results: The dosimetry system was state of the art; however, an evaluation was

still in progress to determine if the thermoluminescent dosimeter chips and the

dose algorithm were appropriate.

Elements of the internal exposure control

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program were in place and it appeared to be functioning adequately. The

program for reporting infractions related to radiological work conditions

needed to be revamped in order to be effective as a tool for correcting

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problems. Other radiological controls appeared to be adequate. The licensee-

has maintained a technically qualified organization.

A new radiation

protection manager was recently selected. An adequate radiation

protection / general employee training program had been implemented.

Some problems were noted concerning timely submittal of Design Change Packages

to the ALARA group.

The licensee had performed comprehensive audits in the area inspected.

A well managed transportation and solid radwaste program had been implemented.

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DETAILS

1.

Persons Contacted

ANO

  • J. W- Yelverton, Director Operations
  • D. W. Akins, Superintendent, Health Physics (HP)

H. N. Bishop, Radwaste Supervisor

  • D. Boyd, Licensing Specialist

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  • 0. Cypret, Senior HP Specialist
  • J. J. Fisicaro, Manager, Licensing ANO-
  • R. E. Green, Dosimetry Supervisor

W. L. Hada, HP Operations Supervisor-

  • R. J. King, Supervisor, Licensing
  • W. C. McKelvy, Superintendent, Nuclear Chemistry
  • D. J. Moss, Radiation Protection /Radwaste Manager
  • T. W. Nickels, Superintendent, Radwaste
  • G. D. Provencher, Manager, Quality Assurance (QA)-

S. P. Robinson, Supervisor, ALARA

T. M. Rolniak, Lead Trainer, HP

  • R. A. Sessoms, Plant Manager, Central

D. J. Wagner, Acting Supervisor, QA-

J. R. Waid, Supervisor, Technical Support Training

Others

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  • C, Warren, Senior Resident Inspector,-NRC-
  • K. Weaver, Resident Office Assistant, NRC

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  • Denotes those individuals present at the exit meeting conducted on

September 28, 1990.

The inspectors also interviewed several other licensee and contractor

employees, including HP, chemistry, QA, and training personnel.

2.

Action on Previous Inspection Findings

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(Closed)OpenItem(313/8936-01;368/8936-01):

Classification'of

Placement of Personnel Monitorirg Devices for External Exposure - This

item was discussed in NRC Inspection Report 50-313/89-36; 50-368/89-36 and

50-313/90-04; 50-368/90-04 and involved the monitoring of the lower leg as

an extremity. As reported previously, the licensee revised

Procedure 1000.031 to reflect the lower leg'to be included as part of the

whole body, but had not corrected Section 8.26 of Procedure 1642.006.to

reflect the change. The 'aspectors verified that this procedure had been

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revised to reflect the change.

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(Closed)UnresolvedItem(313/8947-02;-368/8947-02): This item was

discussed in NRC Inspection Report 50-313/89-47; 50-368/89-47 and involved

the observation of the portal monitor alarms by the~ security officers at

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the secondary guard station.

The inspectors observed individuals as they

passed through the portal monitors and noted that:it appeared that the

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number of security personnel and the attention they gave to the portal

monitor responses had increased since the previous observation and it

appeared adequate to prevent personnel from leaving the site unmonitored.

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(Closed) Violation (313/9004-03; 368/9004-03): . Unauthorized Transfer of

Byproduct Material - This. violation was discussed in NRC Inspection

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Report 50-313/90-04; 50-368/90-04 and involved the transfer of radioactive

materials without possession of a current copy of the transferee's

license. The licensee had obtained an updated copy =of the transferee's-

licensee. The licensee made changes to station procedures requiring that'

verification be made thct the transferee's license is on file and current-

prior to any shipment of radioactive material made to them.

3.

Organization and Management Controls

The inspectors reviewed the licensee's onsite RP organization, staffing,

and assignment of responsibilities to determine agreement with the

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commitments in Chapters 12 and 13.of the Units 1 and 2 Updated Safety

Analysis Reports (USARs), and compliance with the requirements in

Section 6 of the Units 1 and 2 Technical Specifications (TSs).

The inspectors determined there had been no change.to the reporting chain

for the radiation protection /radwaste manager and organizational

responsibilities remained as described in NRC Inspection

Report 50-313/90-04; 50-368/90-04.

In preparation-for the

maintenance / refueling outage scheduled for. Unit 1, the licensee had

contracted for 98 senior and 29 junior HP. technicians, 34 clerks and

44 decontamination personnel.

The 34 clerks would provide additional

support for both the dosimetry group and at access' control points.

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licensee was experiencing difficulty filling all the HP technician-

positions. These problems were related to the. lack of availability of

personnel due to the large number of outages scheduled within the' industry

and the greater than normal number of technicians who did not pass the

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qualifications examination administered by the licensee. The licensee

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stated that work scheduled would be deferred if they did not have HP

technicians available to effectively monitor.the work.

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No violations or deviations were identified.

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4.

Training and Qualifications

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The inspectors reviewed the licensee's training and qualification program

for general employees, HP personnel, and contractor HP technicians,

including adequacy of training and quality of training, qualification

requirements, new employees, and audits and surveillances to determine

agreement with commitments in Chapters 12.5 and 13.2 of Units 1 and 2

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USARs, compliance with the requirements in Sections 6.3 and 6.4 of Units 1:

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and 2 TSs, and 10 CFR Part 19.12, NRC Bulletin 79-19; and the

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recommendations of RGs 8.8, 8.10, 8.13, 8.27, and'8.29; and

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ANSI /ANS 3.1-1978.

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The inspectors reviewed the . licensee's radiation. worker training programs

for permanent plant employees, visitors', and contractors. -The licensee's

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general employee training and radiation worker training appeared to

satisfy the requirements of 10 CFR Part 19.12; and the guidance in

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RGs 8.13, 8.27, and 8.29.

The inspectors reviewed the licensees. training program for HP personne1'

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and radwaste operators, The licensee's training program was being'

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1mplemented in accordance with station procedures and met the commitments

made in response to. IE Bulletin 79-19 for training of radwaste personnel

involved in the transfer, packaging, and transport of low-level

radioactive waste materials.

The inspectors reviewed selected resumes of incoming contract HP

technicians and determined that they met. qualification requirements. The

inspectors noted that the licensee had written criteria for evaluating the

individual's previous experience (Procedure 1012.002, " Contract HP

Technician Selection")

The inspectors noted that the licensee required

individuals to have:

a high school diploma or equivalent, at least 1 year

of technical training, and at least 2 years (4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br /> in..a minimum of 80

weeks) of varied radiological pro;ection experience at a commercial

nuclear power station (or equivalant).

The procedure allowed 1 year

(2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> in a minimum of-40 weeks) of power station experience to be>

substituted for technical experience if the individual had at least.

6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> experience.

The inspectors also noted that the maximum credit

allowed for decontamination experience was raised from 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> to

1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, and the maximum total credit allowable for decontamination,

contaminated laundry, respiratory protection', dosimetry, and radioactive-

waste handling experience was raised from 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> to:1500 hours, in the

latest revision of Procedure 1012.002.

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The licensee is committed to have an individual:as radiation protection

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manager (RPM) that meets the requirements of RG 1.8.- 1975.

RG 1.8 states

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that the RPM should have.a bachelors degree or the equivalent and at least:

5 years of professional experience in applied radiation protection.

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least 3 years of this professional experience should be in applied

radiation protection work in a nuclear facility dealing with radiological

problems similar to those encountered in nuclear power stations,

preferably in an actual nuclear power station.

The inspectors reviewed the qualifications of the new individual assigned -

to the position of radiation protection /radwaste manager. The individual

has a degree in nuclear engineering and approximately 71/2 years

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professional experience at a Naval shipyard and 4 1/2 years as an

evaluator for radiological protection programs at various nuclear

facilities. The later period included a long term assignment (2-3 months)'

at a nuclear power station during a refueling outage.

The inspectors discussed with the licensee the limited experience of the

new RPM with the actual supervision of a power reactor associated HP'

program. The licensee submitted a letter dated October 12, 1990, to NRC.

stating that the RPM would receive-technical support assistance from the.

former corporate HP-(also former AN0_ RPM). This assistance will-be

provided for a minimum of 6 months at which time an evaluation will be

made for the need of continued support.

No violations or deviations were identified.

5.

0A program

The inspectors reviewed the QA surveillance and audit programs regarding

RP, training, and radioactive waste transportation activities to determine.

agreement with commitments in Chapter 17 of the Units 1 and 2-USARs and

compliance with the requirements in Section 6.5.2.8'of the_ Units 1 and 2

TSs.

The inspectors reviewed QA manuals, audit procedures, audit checklists,

audits, and surveillance reports conducted during the period January 1,_

1990, to September 26, 1990, in the above areas. The inspectors also

reviewed audit findings, corrective action tracking and . responses to -

findings, and auditors' qualifications. The specific audits and

surveillances reviewed are listed below:

QAP-3-90 Quality Assurance Program Audit - Health Physics, March 12 -

through May 7, 1990

QAP-4-90 Quality Assurance Audit - Trai_ning (Revised), April 11

through May 25, 1990

90-112

Quality Assurance Surveillance - HP Job Coverage (Weekend,

Unit 2 Power Entry), September 10, 1990

90-002

Quality Assurance Surveillance - Unit 1 Radiological,

Contamination and Hot Particle. Surveys, January 5, 1990

90-018

Quality Assurance Surveillance - Radiological Controls and-

Housekeeping, Units 1 and~2 Auxiliary Building, January 31, 1990

90-023

Quality Assurance Surveillance - Radioactive. Source Control,

February 9, 1990

90-062

Quality Assurance Surveillance - HP Radiation Surveys,-May 2,

1990

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The QA audits and surveillances appeared To be a comprehensive evaluation:

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of the programs reviewed.

Deficiencies that were noted had been resolved

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in a timely manner.

No violations or deficiencies were' identified,

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External Exposure Control

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The inspector reviewed theLlicensee's external control-program to

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determine compliance with Unit 1 TS 6.10, Unit =2 TS 6.11; the requirements

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of 10 CFR Parts 19,13, 20.101, 20.102, 20.105, 20.202,.and 20.401; and the

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commitments.of. Chapter 12 of the USAR.

The inspectors reviewed the licen_see's facilities for processing new _

radiation workers and verified that the licensee obtained individuals'

previous exposure histories and verified completion of radiation worker

training prior to issuing dosimetry.

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The inspectors noted that the licensee used state of the art,

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four-element, thermoluminescent dosimeters-(TLDs). .The licensee _had

received accreditation from the National Voluntary Laboratory

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Accreditation Program in all categories. The accreditation. extends until

January 1, 1991.

The inspectors reviewed the dosimetry processing area

and the licensee's quality assurance techniques and determined that they

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were adequate.

The licensee also conducted a_ quarterly quality assurance-

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verification with the assistance of a vendor. ' Licensee representatives -

stated that they have approximately 18,000 TLDs, which appeared to be a

sufficient supply for-the upcoming outage.

The inspectors:also reviewed

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the licensee's use of multiple TLD packets and extremity monitoring during

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special jobs.

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The licensee's representatives stated that a contractor was performing an

evaluation to determine the adequacy, in certain site-specific

environments, of the TLD chip currently in use.

For example, licensee

representatives had noted in the past.that neutron. doses measured by TLDs

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differed from that predicted from instrument measurements by as much as a

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factor of 10. The licensee stated that if the TLDs are found to be

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appropriate, adjustments to the dose. algorithm will be made, if not,-

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different TLDs will be used and perhaps another. evaluation of.the. spectrum

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of neutron energies will be performed,

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The inspector discussed technician qualifications with the licensee's

representatives and determined that the dosimetry technician in charge of

processing TLDs had recently completed an offsite training course in

dosimetry.

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The inspectors observed a technician performing:a calibration of

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self-reading dosimeters (SRDs) and verified that the licensee had .

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implemented a program of comparison of the exposure recorded by the TLDs:

and the SRDs.

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Licensee representatives stated that they are preparing to initiate th'e -

use of electronic, alarming dosimeters for individuals entering high

radiation areas and would perhaps, in the future,'use them for all people

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entering the radtalogical controlled area (RCA).-

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No violations or deviations were identified.

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Internal Exposure Control

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The inspector reviewed the licensee's program for control of internal

radiation exposure to determine compliance with Unit 1 TS:6.10, Unit 2 TS;

the requirements of 10 CFR Parts 20.103, 20.201, and 20.401; and agreement

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with the commitments in Chapter 12 of the USAR and:the recommendations of

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RG 8.15, NUREG-0041, Industry Standards _ ANSI Z88.2-1980 and ANSI /GCA

G-7.1-1989.

The inspectors reviewed the whole body counting facilities and noted that-

the licensee had shortened counting time on the'two bed-type whole body

counters and were thus able to process more people per time period and yet

maintain adequate sensitivity. The licensee added a third whole body

counter, a standup unit, which was located inside the protected area,

making it more convenient for investigational use than the others which

were located in the training center.

The licensee was required by.procedu're to analyze positive whole body.

counts at least quarterly to identify trends which indicated practices-

contributing unnecessary exposure,.-The inspectors confirmed that the

licensee had implemented a procedure to calculate airborne: radioactivity

concentration using whole body counting results.

The inspectors reviewed policy statements requiring the 'use of enginee' ring

controls whenever possible to lessen the possibility of internal exposure

and reviewed records of air sampling data.. The inspectors also observed

that the licensee used an adequate number of_ continuous air monitors in

various locations throughout the facility.

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The inspectors reviewed portions of the respiratory protection program

including:

fitting, selection, issuance,. return, testing, and

maintenance.

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The inspectors observed the respirator fitting area and noted the use of

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tabletop fit testing devices.

Issuance was from the HP-desk at the

radiological controlled area entrance. The inspectors' reviewed records of

respirator issue and confirmed that individuals receiving respirators were

qualified and that they received respirators of the proper size and type.

Issue procedures called for individuals'to present a laminated' respiratory

qualification card listing the dates of respiratory protection-training;

(differentiating between that for purified, air devices, supplied air, and

self-contained breathing apparatus), physical examination, fit testing-

and respirator size.

The inspectors observed that it was-possible,

under certain circumstances,-for unqualified-individuals to alter the-

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cards and thus appear to have completed the required qualifications. HP

representatives stated that individuals had begun to present unlaminated

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cards at the issue point and HP was initiating new issuance procedures.

utilizing a computer printout listing the status of respiratory protection

qualifications of all personnel. The inspectors reviewed the information

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available on the radiation exposure management (REM)= system and noted that.

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it did not differentiate between the different types of respiratory.

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protection training and hence, could not be used as an issuance tool.-

The inspectors determined that the licensee had adequate' facilities for

decontaminating, cleaning, inspection,. testing, and maintenance-of,

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respiratory protection equipment and verified that respirators ready to be

issued had been inspected within the previous 30. days. -The inspector also

noted that the licensee had programs for the testing of:used respirator

cartridges and portable, filtered ventilation units.

Licenses representatives informed the inspectors of one instanco in which-

a unique fitting used on the breathing air system was removed and another

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fitting was installed.

The licensee representatives believed that the

fitting was replaced by employees of a contractor and were'considering

methods of preventing recurrences.

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No violations or deviations were identified.

8.

Control of Radioactive Material and Contamination, Surveys, and Monitoring

The inspectors reviewed the licensee's program for surveying / monitoring

and controlling radioactive materials to determine' compliance-with Unit 1

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TS 6.10, Unit 2 TS 6.11; the requirements of 10 CFR Parts 19.12, 20.201,

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20,203, 20.205, 20.207, 20.301, and 20.401; and'with'the commitments in

Chapter 12 of the USAR.

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The inspectors reviewed the access control procedures at containment

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access to Unit 1 (designated as CA-1)-and observed the alternate access

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facilities (CA-3), under construction, which will_be used during the

outage. Qualifications of individuals entering the RCA were automatically

verified by computer prior to entry.

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The inspectors noted that the egress area from the personnel hatch at

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containment had been changed to allow more room for the> removal of

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protective clothing by personnel as they exited.

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The inspectors reviewed survey procedures, by HP personnel, of itema prior

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to their release from the RCA and noted that tool monitors were in use for

checking items such as hard hats for contamination.

The inspectors reviewed selected radiation work permits (RWPs) and

determined that RWPs for work to be performed up through approximately the

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first week of the outage had been: completed.

There was no' specific method

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to ensure that RWPs were revised if radiological work conditions changed

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during the course of the job other than feedback from the HP tech covering

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the work (or work area =if full coverage was not provided).

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representatives pointed out that RWPs were good only for two weeks and

survey information was reviewed before renewal.

The inspectors reviewed radiological safety infraction / condition (RSIC)

reports and noted that, in some cases, occurrences taking place as early

as April 1990 had apparently not been investigated andLresolved.

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cases, items had been referred to specific individuals for action, but due

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dates had not been met and apparently action had yet to be taken. The

individual in charge of maintaining the RSIC reports also stated that he

sometimes did not receive copies of the reports and had no wa; ef

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determining at what stage of completion the items were.

Licensee

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representatives acknowledged the problems with the RSIC reports'and stated'

that they were considering ways of improving.the process.

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The inspectors reviewed radiological' survey data and determined that the-

licensee had implemented an adequate program of routine' surveys.

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survey frequency was determined by the radiological protection manager.

In accordance with the licensee's procedures, at least 10 percent of the

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contamination surveys were counted for alpha contamination.

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The inspector confirmed that portable radiation survey instruments were

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response checked daily.

Licensee representatives estimated that between

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85 to 95 percent of the portable urvey instruments were operable and .

available for use.

The inspectors confirmed that it appeared an adequate

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supply was available. The inspectors also reviewed the instrument

calibration facility, interviewed personnel,yand reviewed selected:

calibration procedures. The instrument and controls (I&C) department

performs the calibration of portable survey ~ instruments, portable air

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samplers, personnel contamination monitors, portal" monitors, tool

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monitors, continuous air monitors, and particulate-iodine-noble gas

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monitors. Calibration of such-items as radiation and process monitors ~are

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performed by the unit I&C personnel. Another staff member has recently

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been added to the calibration staff, which is not HP-specific, bringing

the total to three.

No violations or deviations were identified.

9.

Maintaining Occupational Radiation Exposures ALARA

The inspectors reviewed the licensee's program for maintaining

occupational radiation exposures ALARA to-determine agreement with the

commitments in the Units 1 and 2 USARs; compliance with the requirements

of 10 CFR Parts 20.1(c); and agreement with the recommendations of

RGs 8.8, 8.10, 8.27, and Information Notice (IN) 83-59, 84-61, 86-44,86-107, and 87-39.

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The licensee's ALARA program is well defined-in Administrative

Procedure 1000.033 and Section 1612.000 of the plants' operating

procedures. The HP group ALARA supervisor is responsible for site ALARA

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activit;es.

During normal plant operations the ALARA supervisor is

assisted by three senior HP technicians and five planning and scheduling

coordinators. The licensee had planned to supplement the ALARA staff with

four senior HP contract technicians during the-maintenance / refueling

outage on Unit l'.

The licensee has a hot spot tracking system and has attempted _to reduce

the radiation intensity at several locations.

During September 1990, of

the 5 flushes made, 3 of the 32 hot spots in Unit I were reduced

significantly, from 1000 to 150 millirem.per hour (mrem /hr)'. The licensee

had more success in Unit 2 where 7 of the 16 hot spots were reduced.:from

2000 to 6 mrem /hr. The intensity of the highest hot spot in Unit 1 is-

40,000 mrem /hr at contact and 1600 mrem /hr in Unit 2.-

The licensee has

plans to reduce additional hot spots during the Unit'l

maintenance / refueling outage.

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The inspectors had determined that the licensee had_ completed the-

" surrogate tour", which is a laser video dicc system film to assist .the

ALARA group. The licensee expects to save person rem by reducing the time

required to locate exact work areas and identifying areas of; higher

exposure levels to work crews prior to their entry into the area.

The inspectors discussed the lack of a centralized briefing' room for work

crews where prejob and postjob reviews could be conducted.

The licensee

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had a small room in the alternate access facility "CA-3," adjacent to the

reactor building equipment hatch, set aside for prejob briefings. This

area did not appear adequate for all-ALARA briefings.

The inspectors discussed with licensee representatives the lack of work

packages for design changes that had been received from the engineering

department. Only 70 of the 80 design change packages had been received

and the outage was scheduled to- start in 3 days. The lack of timely

submittal of design change package prevents-adequate ALARA evaluations

regarding worker and HP support,-shleiding requirements, and estimated-

person-rem exposure for the jobs.

The licensee had made several improvements to the ALARA program since the

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last NRC inspection. Job history files had received more attention and

had been entered-into the, computer base. The licensee had contracted'for-

12 remote television cameras, 10-with audio capability, for the outage.

These cameras will be placed within the reactor building and the master

console will be located-in the CA-3 access facility. The licensee had

also purchased alarming dosimeters for use by personnel in high radiation

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areas.

No violations of deviations were identified.

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10.

Transportation Activities

The inspectors reviewed the licensee's radioactive material transportation

program to determine agreement with the commitments _made in response to

NRC Bulletin 79-19, ins 79-21, 80-32, 83-10, 84-14, 84-50, 85-46, and-

87-31; and compliance with the requirements of 10 CFR Parts 20, 30, and

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71; and 49 CFR Parts 171 through 189.

The inspectors reviewed all records of radioactive material shipments made

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from January 1 through September 24, 1990,'for completeness of shipment

records. The inspectors determined that the. licensee's procedures had

been appropriately updated to incorporate the revisions to NRC and.

Department of Transportation (DOT) regulations, changes to burial site

acceptance criteria, and applicable items from ins.

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The inspectors reviewed the licensee's procurement of DOT and NRC

certified packages. The inspectors noted that the licensee normally ships

low specific activity waste in steel boxes as strong-tight containers or

in steel containers inside an NRC certified package.

The inspectors

determined that the licenses maintains current documents on manufacture

design, use, maintenance, testing,' and NRC certificate of compliance for

all packages the licensee is' registered to use.

The inspectors verified that the licensee had established procedures and

checklists for the preparation of radioactive material and_ waste

shipments. These procedures included requiring-a visual inspection of the

packages prior to use or loading the package, instructions for closing and'

sealing the packages, the package's identification and weight, labeling-

requirements for the appropriate type of package, and determining the

curie content, radiation and contamination limits for packages. The

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licensee routinely uses quality control hold or checkpoints during

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preparation of the package.

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The inspectors determined by discussions with licensee representatives

that none of the ANO radiation material or waste shipments had been

involved in an accident or incident.

No violations or deviations were identified.

11. Solid Radioactive Waste Management

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The inspectors reviewed the licensee's program for processing, control,

and onsite storage of solid radioactive waste for agreement with the-

commitments in Chapter 11'.4 of Units 1 and 2 USARs; compliance.with the

requirements in Unit 1 TS 4.29.4 and Unit 2 TS 3.11.4, 10.CFR'

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Parts 20.301, 20.311, 61.55, and 61.56; and the recommendations of NRC

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branch technical position papers on low level radioactive waste (LLRW)

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classification and waste form characterization and ins 87-03 and 87-07.

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The inspectors reviewed the licensee's computerized program for management

of waste processing and packaging activities.

The licensee's computer-

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program included the latest revisions to 49 CFR requirements regarding-

reportable quantities and emergency response:information. .The licensee-

stated the computer program vendor supplies, updated programs when the

regulatory requirements are changed.

The licensee performs-annual

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evaluations of waste streams, samples are sent:to a qualified vendor's

laboratory for analysis and. development of isotopic correlation factors.

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The licensee's LLRW characterization and classi_fication program is well

documented in accordance with station procedures.

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The licensee ships dry active waste,.compactable and noncompactable-

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radwaste, to a vendor for additional.. segregation, incineration, and super

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compaction. This process has reduced:the total volume of~LLRW being

delivered to the burial site,

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The inspector noted during tours of the licensee's facilities that LLRW

was being stored outside, unprotected, by the old radwaste building. This

_

included 24 boxes low level contaminated soil, drums of. concrete rubble,

solidified oil,-and spent resins.

The licensee was storing new unused

boxes inside the radwaste building.

The licensee stated they would

reevaluate the outside storage of LLRW.

No violations or deviations were identified,

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12.

Exit Meeting

The inspectors met with the senior resident inspector and licensee

representatives identified in paragraph 1 of this report at the conclusion

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of the inspection on September 28, 1990. The inspector summarized the

scope of the inspection and discussed the inspection findings as presented

in this report. The licensee did not identify.as proprietary any of the

materials provided to, or reviewed by, the inspectors during the

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inspection.

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