ML20125D895

Insp Rept 50-483/92-25 on 921102-06.Noncited Violation Noted.Major Areas Inspected:Organization,Mgt Controls & Training,Qa Audits & Surveillances & Processing of Solid Waste

ML20125D895
Person / Time
Site:	Callaway
Issue date:	11/02/1992
From:	David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20125D866	List: ML20125D864 ML20125D878 ML20125D895
References
50-483-92-25, NUDOCS 9212160082
Download: ML20125D895 (11)

See also: IR 05000483/1992025

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. U.S. NUCLEAR REGULATORY COMMISSION

RM10N III

Report No. 50-483/92025(DRSS)

Docket No. 50-483 License No. NPF-30

Licensee: Union Electric Company

Post Office Box 149

St. Louis H0 63166

Facility Name: Callaway County Nuclear Station

Inspection At: Callaway Site, Callaway County, Missouri

Inspection Conducted: November 2-6, 1992

Inspector: Ld. Odf b n./z /> t.

D. W. Nelson / Date

Radiation Specialist

Approved By: LO. hkk it/L/f3_

W. Snell, Chief, Date

Radiological Controls Section 2

in meetion Summary

Inspection on November 2-6. 1992 (Recort No. 50-483/92025(DRSS))

Areas Insnected: Routine announced inspection of the radiation protection,

solid radioactive waste and transportation programs including: organization,

management controls and training; quality assurance (QA) audits and

surveillances; processing of solid waste; waste classification methodology and

transportation of radioactive rnaterials and waste (IP 83750,86750).

Besults: One violation for two failures to survey packages containing

radioactive material upon receipt (Section 9). One non-cited violation for

failure to register as a user to transport licensed material in a package for

which a certificate of compliance had been issued by the NRC (Section 6). One

Inspection Followup Item was identified for a lack of documentation for the 10

CFR 71 QA program (Section 6).

Areas for which improvement appears to be merited are training for new

supervisors (Section 4), the review of radioactive waste and transportation

procedures (Sections 7 and 8), control of containers in the radioactive waste

building (Section 10) and the receipt of packages containing radioactive

l material (Section 9).

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l A number of strengths were identified including the 1992 QA audit of Radwaste

l (Section 5), tne computerized Suggestion Occurrence Solution system (Section

l 4), and heusekeeping in the generally accessible areas of the auxilin y and

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radioactive waste buildings (Section 10).

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1. Persons Cont 3cted

• W. Campbell, Manager, Callaway Plant

• F. Cruickshank, Supervisor, Rad / Chemistry

• M. Henry, QA Engineer

• M. Evans, Superintendent, Training

• G. Hamilton, Supervisor, Quality Assurance

• G. Hughes, Supervisor, Independent Safety Engineer Group

• J. Laux, Quality Assurance Manager

• R. Miller, Supervisor, Radwaste/ Environmental

• J. Neudecker, Supervisor, Health Physics Operations

• S. Petzel, Engineer

• J. Peevy, Manager, Operations Support

• J. Polchow, Superintendent, Chemistry and Radioactive Waste

• R. Roselius, Superintendent Health Physics

• D. Calhoun, Resident inspector

The inspector also interviewed other licensee personnel during the

course of the inspection.

• Denotes those present at the exit meeting on November 6, 1992.

2. General

This inspection was conducted to review aspects of the licensee's

radiation protection, solid radioactive waste and transportation

programs. The inspection included tours of radiation controlled areas,

observations of licensee activities, review of representative records

and discussions with licensee personnel.

3. Licensee Action on Previous Inspection Findinas:

IC_lpn d) Violation (50-483/920ll-02(DRSS)): failure to perform a

written safety evaluation prior to storing radioactive waste in a yard

outside of the Radwaste building. Since the inspection, the licensee

has moved all of the stored waste into the Radwaste building. This

item is closed.

4. Oraanization. Management Controls and Trainina (IP 83750. IP 86750)

The inspector reviewed the licensee's organization and management

controls for the radioactive waste management, solid radioactive waste

and transportation programs, including: organizational structure,

staffing, delineation of authority and management techniques used to

implement the program and experience cor.cerning self identification and

correction of program implementatio n.aknesses.

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. On December 1,1002, the Superinte.. dent of Training will be nameu the

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new Superintended, of Health Physic:. llistorically, the Superintendent

U of Health Phytics also served as the Radiation Protection Manager (RPM).

.. During a e ' 1992 inspection (Inspection Report 50-483/920ll(DRSS)) the

f inspector raised a concern about wheth 'ar not the Seperintendent of

i3 Training would meet the experience re< . , ataents of Hulatory Guide (RG)

1.8 to serve as the Rcdiation Protect'.*m Manager. Subsequent to the

July MM inspection, NRC management rm;iewed the Superintandent of

e Trainir.:'s resume and determined that the he would not be v alified to

serve as RPM due to a lack of experience. This information was conveyed

, to the licensee. As a result, the iicensee has decided to temporarily

assign the title of RPP. to the Supervisor of Health Physics Operations.

The title of RPM will be reassigned to tne Superin'endent of Training

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(after he becomes the new Superintendent of Health Physics) on'/ after

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he F ns i eacagh experience to satisfy the requirements cf the RG.

In Jun of 1992 the Supervisor of Radioactive Waste and Iransportation

(RW&T) was retssigwi to Quality Assurance. The Environmental EnM 1er

asumed thc responsibilities of the Supervisor RW&T and was giver 9

e' titie of Supervisor of Radioactive Waste / Environmental. A review .he

new supervisor's qualifications indicated that he was only margirr <

qualified to supervise the radioactive waste and transpurtation

programs. During the review, the inspector noted that although the '

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supervisor had an extensive background in N processing and

transportation of hazardous materiels he ha less than one year of

experience working with radioactt wadi w 'or supervising activities

involving radioactive materialt 1 adM , his radiological training

we ' , ei to the in-house RP trat.ing program. ANSI 3.1.4.3.2-

le gares, in part, that supervisors shall have four years of

. expe, ,ence in the craft or discipline they supervise. The new

supervisor had not met that standard. However, the NRC has taken the

pos' tion that specialists (supervisors) assigned to narrow, specific

areas of respansibility with small support staffs would not be expectea

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to meet the requirements of the standard. (See HPPOS-172, f"! REG /CR-

5569, "dealth Physics Positions Data Base," May 1992.) In this case,

the supervisor ha'i been assigned to a specific narrow area eith a

relatively small staff. Therefore, the NRC has determined that although

the supervisor of Radioactive Waste / Environmental does not meet the four

years of experience specified in ANSI 3.1, h 4 experience is adequate

for him to assume this position. However, t..e licensee is responsible

for ensuring that these specialists (supervisors) are given sufficient

turnover time and training to make up for their lack of experience. The

inspector noted that the supervisor had spent approximttely one year

working with the previous supervisor and had received approximately

three months of ferr..al turnover time. The supervisor had not, however,

received any additional training beyord the in-house RP core curriculum.

In light of the Supervisor's lack of experience the inspector identified

this as :an area were improvement is warranted.

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Two Raa/ Chem supervisors were reassigned in June of 1992, to new

positions within thn Radwaste group. One Rad / Chem supervisor, formally

assigned to training, was reassigned to radioactive waste and

transportation (RW&T) and the othe:, formally assigned to Chemistry, was

reassigned to radioactive waste packaging. Both individuals appeared to

be qualified to hold their new positions; both had extensive backgrounds

in radiation protection. The inspector noted, however, that only one of

the supervisors (RET) had received training beyond the in-house core RP

program in addition to receiving an extensive amount of turnover time in

his new program. The lack of training beyond the RP core curriculum for

new supervisors was identified as an area where the program could be

improved. This issue was discussed at the exit meeting.

There were 11 Rad / Chem technicians assigned to Radwaste, all of which

had graduated from the licensee's RP apprenticeship and core training

programs. These same technicians have remained in the program since the

last radioactive waste inspection.

The licensee's computerized Suggestion Occurence Solution (S0S) system

is excellent. A description and analysis of each SOS is entered into

the database. Corrective actions are documented and da Wd for

implementation. The system is easy to access; enter a few simple

commands on any computer and you have access to the SOS's written for

the year. Using the resident's computer, the inspector reviewed all of

the SOS's written in 1992 to document concerns at,out the radioactive and

transportation programs.

No violations or deviations were identified.

5. Audits. Surveillances and Self Assessments (IP 8675Q1

The inspector reviewed the results of Quality Assurance (QA) audits and

surveillances conducted by the licensce :ince the last radioactive waste

and transportation inspection. The inspector reviewed the extent,

thoroughness and results of one Quality Assurance (QA) audit a..J three

surveillances performed on the radioactive waste program.

The inspector reviewed the last audit performed en the radio".cive waste

program (OA audit AP92-004 (March 16, 1992)). The audit was excellent;

it was inforrative, comprehensive and corrective actions were taken in a

timely manner. The audit found that programs within radioacthe waste

had been effectively implemented in accordance with regulatory and

procedural requirements. There were, however six Suggestion Occurrence

Solutions (505) written as a result of the audit. Several included:

a. Bags containing potentially contaminated trash were not being

sur. eyed prior to leaving the Radiological Control?cd Area (RCA).

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b. Several errors were found in the Radwaste storage logs. Radiation

level survey results for a number of barrels were missing from the

Radwaste Shipment Storage and Stovepipe Drum Storace Logs and >

radiological data for a shipment of a 1040 liner was missing from

another log.

c. Several radwaste procedures needed clarificction and additional

instructions. For example, all solid waste was being t c 9ated as

potentially contaminated waste whether it was potentially

contaminated or not. This was creating a lot of additional work

for radwaste. The SG3 recommended t' t this policy be changed.

The ir.spector did note one entry in the a.d h that should have been

reported as a deficiency. On August 24, 1992, a Notice of Violation was

issued to the licensee for failing to perform a safety evaluation far

storing radioactive waste in an area outside the radwaste building. The

audit assessed the adequacy of the yard west of the radwaste building

for the storage of rada ste and found that "it appears Callaway Plant is

not in full compliance with regulatory requirements pertaining to

storage of low-level radwaste in the yard west of the radwaste

building". The auditor did an excellent job discussino the reasons for

reaching this conclusion. The team decided not to issue a SOS; the team

was told that another SOS had been written to address the problem and

corrective action had been initiated. Later it was learned that

although a SOS had been written, corrective action had not been

initiated. In retrospect, the team should have written an additional

TOS. This issue was discussed at the exit meeting.

The inspector reviewed the foliowing three surveillances:

• Surveillance SP91-034 (November 2, 1991) of the status of unused

radwaste containers.

• Ser -illance SP9?-080 (August 28,1992) to verify that

Radwaste/Chemistiy records have been completed with valid

information.

• Surveillance SP92-093 (October 14,1992) to assess the

effectiveness and adequacy with which Radwaste procedures

implement the new 10 CFR 20.

The three surveillances were thoroup, substantive in aature and

corrective actions were taken in a timely manner. One SOS suggestion

for improvement was issued as a result of Surveillance SP92-080 and two

were issued as a result of Surveillance SP92.093. Due to the scope of

the 1992 audit there were fewer surveillances performed in the first

nine months of 1992.

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No violations or deviations were identified.

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6. 10 CFR 71. Suboart H (IP 86750)

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H CFR 71, Subpart H, requires in part that a license shall establish,

I maintain, and execute a quality assurance program satisfying each of the

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applicable criteria of 10 CFR 71.101-137 of Subpart H and satisfying any

specific provisions that are applicable to the licensee's activities,

including procuroment of packaging. The licensee's established 10 CFR

50, Appendix B, QA program meets the requirements of the Fubpart if the ,

program satisfies each of the applicable criteria. To satisfy the

requirements the licensee must include and address all of the applicable

elements for trarsport packages. The inspector reviewed the QA program

for compliance.

The inspector reviewed:

• Operating Quality Assurance Manual

• QA Planning Guide for the functional Arer. of Radioactive Waste

QAPG-RW (incluoes packaging and shipping of radioactive waste)

• Critical Attributes for implementing the Planning Guide

• QA audit of one of the licensee's 10 CFR 71 package suppliers

• Commitment Display Report for commitment number 42667 (10 CFR 71

QA program)

• Letter to the NRC dated September 6, 1991 requesting an amendment

to the licensee's QA program

• Radwaste procedures for shipping 10 CFF. 71 packages.

The inspector concluded after the review that although the licensee had

complied with the requirements of Subpart H, the licensee lacked a

" bridging" document or set of documents that described in some detail

their 10 CFR 71 QA program and the manner in which the program would

meet the requirements of the Subpart. For example, commitment number

42667 lists those activities which fall within the licensee's Part 71 QA

program and those activities which are the responsibility of tne vendor.

It also states that the licensee is responsible for ensuring that all

transportation activities meet the requirements. The document does not,

however, describe the manner in which those responsibilities will be

met. The QA manual states in part that measures shall be established to

control the shipping of radioactive materials in accordance with 10 CFR

71. The manual does not describe those measures. The Critical

Attributes was the only document reviewed that specifically addressed a

10 CFR 71 requirement. Critical Attribute 2715, requires in part that

the QA auditor verify the existence of a certificate of compliance and

that the care of containers is in accordance with manu'setures

recommeruations. Failure to address or describe all of the applicable

elements of Subpart H was identified at the exit meeting as a weakness

in the program. This issue will be reviewed during a future inspection

(Inspection Follow-up Item 483/92025-01).

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The inspector reviewed a 1988 QA audit of the licensee'.< ') CFR 71

transport package vendor, Westinghouse Radiological Serv.ces. The audit

was comprehensive and substantive in nature. The audit identified three

findings and four comments all of which were corrected within 30 days of

the audit.

The inspector reviewed five 10 CFR 71 package shipping procedures (RTS-

ZZ-CH001, CH002, CH003, CH004, and CH005); one for each of the type B

packages. The procedures were comprehensive, user friendly and included

all of the Quality Control requirements.

During a review of the 50Ss the inspector noted that on three separate

occasions the licensee shipped radioactive material in a 10 CFR 71

package (10-10 cask) without first registering as a user (S05 92-1933).

The licensee c i have a copy of the " Certificate of Compliance" and had

followed all of the other conditions applicable to 10 CFR 71. The

shipments were made on November 4, 1988, April 27, 1989, and June 3,

1991. When the licensee recognized that it had failed to register as a

user they immediately sent a letter to the NRC to correct the

deficiency. The licensee later learned that, sometime in 1988 or 1989,

the cask had been modified and recertified under a new identification

number. The licensee had been registered under the old 10 number and

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had not been notified of the change. The shipping procedures, however,

require that the licensee verify oefore each shipment that the facility

is listed as a user. Failure to register as a user is a violation of 10

CFR 71.12. Since tSe licensee identified the violation and the

corrective action taken appears to be adequate, the violation meets the

non-citing requirements of 10 CFR 2, Appendix C. A review of the

records indicated that the licensee had current Certificates of

Compliance for each package and were on each package's users list.

One non-cited violation was identified. No deviations were identified.

7. So!id Radioactive Waste (IP .96750)

a. M Lt.lreatment

There are four main solid waste streams at the facility. They are

spent resins, evaporator bottom residue, spent filters and Dry

Active Waste (DAW).

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The licensee uses the Radlock 500 system to dewater resins. The

wet spent resin is transferred to a high integrity container (HIC)

and the Radlock system dewaters the resin in the HIC. The

licensee purchased the Radwaste Volume Reduction (RVR) 800 system

to process their wet evaporator bottom residue. The system

collects, dries and mixes the residue with hot paraffin. The hot

mixture is transferred to 55 gallon drums for shipment. Spent

filters are first drained and then transferred to filtered HlCs to

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dry. DAW is shipped to one of two vendors, Scientific Ecology

Group and Quadrex, for incineration and/or supercompaction. HICs

and crums are shipped directly to a the burial site. For DAW, the

vendor is responsible for disposal following treatment.

b. Waste Classification

The licensee uses RADMAN, a computer based program, to calculate

isotopic activities for each shipment. The program calculates

scaling factors based on the vcndor supplied isotopic analyses of

each waste stream. Annually, samples from each waste stream are

sent to a vendor for isotopic analyses. The licensee will send

additional samples if conditions change within the plant or a new

waste stream is generated. The results of the analyses are fed

into RADMAN and the program uses the data to calculate the scaling

factors for each stream. For spent resins, HIC isotopic activity

is based on the scaling factors and the weight / mass of the waste

in the HIC. For DAW and filter shipments, isotope activities are

based on the scaling factors and a container dose-to-curie

conversion. For RVR shipments, representative core samples are

obtained and analyzed. If the analyses match those of the vendor

the results are fed into RADMAN and the isotopic activities for

each drum are calculated. RADMAN performs all of the required

calculations for each shipment and is capable of generating many

of the shipping documents. Many otner licensees are using RADMAN

and it appears to te an excellent program.

Since the :ast radioactive waste inspection, several problems have arose

with regard to their 10 CFR 61 laboratory vendors (S0S 92-1939). In

December 1991, solid radioactive waste samples were sent to their vendor

for analysis and after waiting several months for the results the

licensee was toid that the vendor could no longer perform the analyses.

Further samples were collected and sent to another vendor. Upon receipt

of the results, the licensee determined that the liquid evaporator

bottom sample gamma results were too low by a factor of 100 when

compared to the in-house analysis and the transuranic and beta results

were too high. An investigation conciudad that the laboratory had

allowed the solids in the sample to settle, prior to the analysis, and

this had effected the sample's geometry with respect to the detect;r.

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Since the other results were in agreement with past analyses the

licensee core sampled ten additional RVR barrels, composited the samples

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and sent the composite to the vendor for analysis. The results of this

analysis agreed with past analyses.

The inspector noted that a QA audit had not been performed on either of

the vendor labs. This issue was discussed at the exit meeting.

Following the inspection, the inspector was told that QA was planning to

conduct a surveillance on the Radwaste program to determine if audits of

sendor laboratories were needed and/or required.

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The inspector reviewed selected radioactive waste and transportation

procedures. The procedures appeared to be comprehensive e'd user

friendly. With one exception, each of the procedures had 9 en reviewed

and/or revised within the previous 12 months. The lone ext.eption was

procedure RDP-ZZ-00013, 10CFR61 Sampling Program. The procedure had not

been reviewed since 1988. The inspector identified several errors in

the procedure and noted that it could not have been used as written.

The inspector was told that another procedure (RTS-HC-Oll30) had been

written to replace RDP-ZZ-00013 but that procedure had not been formally

approved. Recognizing the requirement for procedural " adherence" and in

light of the recent decision to drop the requirement for a biannual

review of all procedures, the licensee has decided to reconsider all of

their procedural review options. Even though one procedure in need of

revision does not indicate a weakness in the whole prC ram, the need for

reviewing all of the radioactive waste and transportation procedures was

discussed at the exit meeting.

No violations or deviations were identified.

8. Transportation of Radioactive Material (IP 86750)

A review of the records indicated that the licensee had made 14

radioactive waste and 40 radioactive materials shipments beginning

January 1, 1992. The inspector noted that none of the shinments were

found to 5 in violation of any of the NRC, CGT or State requirements.

The inspector reviewed selected radioactive waste and radioactive

materials shipments for the adequacy of surveys; shipping documentation;

package marking and labeling; package blocking and bracing; vehicle

placarding and driver's instruction. In each case, the licensee had met

all of the regulatory requirements.

No violat'ons or deviations were identified.

9. Receipt of.R(dioactive Material (IP 83750)

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In Inspection Report 483/92006(DRSS), a non-cited violation and an open

item (0 pen Item 483/92006-03(DRSS)) were identified for failing to

survey incoming packages within time frames specified in procedure hip-

ZZ-02002. In both cases, storekeepers had failed to recognize that the

packages contained radioactive material. During a subsequent

inspection, the licensee indicated t' their vendors had been

instructed to attach labels to packages indicating the presence of

radioactive material and storekeepers had been trained to recognize

packages containing radioactive material. The inspector closed the open

item in Inspection Report 483/920ll(DRSS). Since that inspection; two

similar incidents have occurred involving the receipt of packages

containing radioactive material. In both cases, the packages were not

surveyed prior to their release to other areas within the p1 ant as

required by HTP-ZZ-02004 and HTP-ZZ-02002 (SOS 92-1748 and SOS 92-1579).

These procedures require that upon receipt of a package containing

radioactive material, including the receipt of radioactive sources, the

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warehouse will notify Health Physics. Upon notification, Health Physics

shall perform a survey within three hours if the package was received

during normal working hours or within eighteen hours if received after

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! In one case, a set of radioactive sources was received on September 9,

1992, and the vendor had failed to attach the required label and the

storekeeper had failed to recognize that the package contained

radioactive laterial. In the second case the warehouse received a

radioactive 55 gallon drum on July 22, 1992, and eve though the

container was clearly marked as containing radioact;,e material, the

storekeeper had failed to notify HP prior to its release from stores,

in both cases surveys were net completed within three or eighteen hours.

These cases indicated that the licensee's corrective actions from the

earlier incidents had been inadequate. The inspector noted, however, -

that the licensee's procedures go beyond the regulatory requirements of

10 CFR 20.205; limited quantity shipments are exempt from the surveying

requirements. Recognizing the need to take additional corrective

action, the licensee conducted an additional training seminar for the -

stcrekeepers. The two failures to survey the packages are violations o'

Technical Specification 6.8.1 for failure to implement written

procedures. (Inspection Follow-up Item 483/92025-02.)

No violations or deviations were identified.

10. P1 ant Tours [IP 83750. IP 86750)  ?

The inspector toured the Hot Machine Shop (HMS) and the auxiliary and

radwaste buildings. The inspector observed the following:

• Significant improvements were observed in housekeeping practices

in the Hot Machine Shop and the auxiliary and radwaste buildings.

The inspector did find some debris (gloves and a towel) on the

4 floor in the Hot Machine Shop and the area needed some additional

work. Housekeeping in the radwaste and auxiliary buildings had

improved from poor to excellent in many areas of both buildings.

• Many c:ntaminated rooms in the radwaste building had been

decontaminated. In addition, in those areas where total

decontamination was problematic (pumps on skids for example) total

surface contamination levels had been reduced significantly.

• The inspecter found multiple. examples of mislabeled containers

during a tour of the r:dwaste building. The inspector found old

dose rate and shipping labels on empty drums, drums with multiple

labels or markings, empty drums without labels and drums with no

description of the contents. During a review of tne S0S's, the

inspector noted that the Radioactive Waste group had written a SOS

in October of 1992 documenting many of the same problems observed

during the tour (S0S 92-1937). As a result of the SOS and the

need to ship all of their radioactive waste before January 1,

1993, many of the drums were opened to see what was in them. The

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', SOS concluded in part that plans and procedure changes need to be

made to prevent a recurrence of these problems. The inspector

concurred with this conclusion and will review the corrective

actions taken in subsequent inspections. Inspection Follow-up

ltem 483/92025-03.

No violations or deviations were identified.

11. Exit Interview (IP 83750. IP 86750)

The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on November 6,1992, to discuss the

scope and findings of the inspection.

During the exit interview, the inspector discussed the likely

informational content of the inspection report with regard to documents

or processes reviewed by the inspectors during the inspection. Licensee

representatives did not identify any such documents or processes as

proprietary. The following matters were specifically discussed.

a. Inspector concerns regarding the qualifications and training of

new supervisors (Section 4).

b, l'1spector concerns regarding the implementation of the 10 CFR 71

Subpart H, QA program (Section 6).

c. Inspector concerns regarding the receipt of packages containing

radioactive material (Section 9).

d. Inspector concerns regarding the control of containers in the

Radwaste building (Section 10).

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