ML20148B589

Insp Repts 50-445/97-11 & 50-446/97-11 on 970407-10.No Violations Noted.Major Areas Inspected:Plant Support,Solid Radwaste Mgt & Radioactive Matls Transportation Programs

ML20148B589
Person / Time
Site:	Comanche Peak
Issue date:	05/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148B585	List: ML20148B580 ML20148B589
References
50-445-97-11, 50-446-97-11, NUDOCS 9705130161
Download: ML20148B589 (9)

See also: IR 05000445/1997011

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j ENCLOSURE

!- U.S. NUCLEAR REGULATORY COMMISSION

j REGION IV

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i Docket Nos.: 50-445

i 50-446

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License Nos.: NPF-87

l NPF-89

Report No.

50-445/97-11

( 50-446/97-11

Licensee: TU Electric

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! Freicty: Comanche Peak Steam Electric Station, Units 1 and 2

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Locatiori: FM-56

Glen Rose, Texas

Dates: April 7-10,1997

Inspectors: L. T. Ricketson, P.E., Senior Radiation Specialist, Plant Support

Branch

G. L. Guerra, Radiation Specialist, Plant Support Branch

Approved By: Blaine Murray Chief, Plant Support Branch

Division of Reactor Safety

ATTACHMENT: Supplemental Information

9705130161 970500

PDR ADOCK 05000445

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EXECUTIVE SUMMARY

Comanche Peak Steam Electric Station, Units 1 and 2

NRC Inspection Report 50-445/97-11; 50-446/97-11

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. I

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Plant Sucoort j

• The solid waste management program was implemented well (Section R1.1).

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• The licensee implemented the transportation regulation revisions properly. A good

program for the transportation of radioactive materials and radioactive waste was l

maintained (Section R1.2).

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• The licensee's procedures were very detailed and provided clear guidance. The l

transportation procedures implemented the revisions of 49 CFR (Section R3). i

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• The individuals responsible for conducting the radioactiv'e waste transportation

program activities were knowledgeable of regulatory requirements and software i

utilization constraints (Section R4). i

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• All workers participating in the preparation and packaging of radioactive materials l

and radioactive waste were appropriately trained (Section R5).

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• The organization and staffing of the licensee's radiation protection department was I

appropriate to im 'oment the radioactive waste and transportation programs

(Section R6). l

• An excellent assessmant was performed by a contractor of the solid waste

management and transportation activiti<ss; however, the licensee had not verified

through oversight activities that the revisions to transportation regulations were

implemented correctly (Section R7).

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Report Details

IV. Plant Support

R1 Radiological Protection and Chemistry (RP&C) Controls

R 1.1 Solid Waste Mananement  !

a. Insoection Scone (86750)

The inspectors interviewed the radioactive materials controls supervisor, toured

plant facilities, and reviewed records associated with the storage and ,

characterization of radioactive waste streams. I

b. Observations and Findinas

The licensee's warehouse C and the vault storage yard were used for temporary  ;

storage of low level radioactive waste. The areas were properly posted and I

controlled. No problems were identified with these storage locations.  !

The inspectors noted very good housekeeping within the radiological controlled

area. Waste storage areas were controlled and posted, properly.

During tours of the plant and warehouse C, the inspetors found some minor

discrepancies. These discrepancies included the locations of some radioactive

waste containers not matching the present inventory and the failure to include some

of the containers in the inventory list. The licensee corrected these discrepancies

identified by the inspectors and initiated a review of the inventary procedure for

possible enhancement. No regulatory issues or safety consequences were

associated with the discrepancies in the accountability records.

Waste stream sampling and analyses was performed as required. The licensee used

an independent laboratory for analysis of its identified waste streams. Scaling

factors were computed and the licensee's computer program data base was

updated routinely.1he inspectors concluded that this portion of the licensee's

program was similar to those in the branch technical positions on waste

classification and waste form, and was conducted as required.

Waste classification was performed with the aid of computer software. The

inspectors reviewed examples of waste classification documcatation and identified

no problems.

c. Conclusions

The solid waste management program was implemented well.

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R1.2 Transportation of Radioactive Materials

a. Inspection Scope (Tl2515/133,86750)

The inspectors observed shipping operations and reviewed selected examples of

shipping documentation.

b. Observations and Findinas

Opportunities for performance-based inspection were limited because of the scarcity

of radioactive shipments during the week of inspection. A limited-quantity shipment

containing radioactive samples was prepared by licensee representatives. The

inspectors did not identify problems with the shipment preparation or

documentation.

Inspection of selected examples of shipping documentation confirmed that the

revisions to the transportation regulations were implemented properly. Included in

the examples were items shipped as surface contaminated objects and as low

specific activity. The inspectors also confirmed that the licensee successfully

implemented the use of SI units, required after April 1,1997, on packaging and

shipping documentation.

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c. Conclusions

The licensee implemented the transportation regulation revisions properly. A good  !

program for the transportation of radioactive materials and radioactive waste was

maintained.

R3 Radiological Protection and Chemistry Procedures and Documentation

The licensee's procedures were very detailed and provided clear guidance. l

The transportation procedures had been revised to implement the revisions of  !

49 CFR. However, there were minor examples in which additional revisions were

.needed, because the procedures included the errors originally published in the

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Federal Reaister. - None of the errors were significant enough to adversely affect

the licensee's radioactive materials transportation program. The licensee promptly a

initiated the required revisions to the procedures. l

R4 Staff Knowledge and Performance

Through interviews and discussions, the inspectors determined that the individuals  !

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responsible for conducting the radioactive waste transportation program activities

were knowledgeable of regulatory requirements and software utilization constraints.

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R5 Staff Training and Qualification

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a. inspection Scone (Tl2515/133,86750)

The inspectors reviewed the periodic training of individuals that had taken part in

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the preparation and packaging of radioactive materials for transportation. Also, the

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inspectors reviewed the actions the licensee had taken in response to Generic

Letter 95-09.

b. Observations and Findinas

The inspectors confirmed that individuals participating in the preparation of

radioactive material shipments had periodic retraining within the previous two years.

The training provided most recently to the licensee's staff was provided by a

contractor. The training material was comprehensivo and addressed the revisions in

transportation regulations, effective April 1,1996.

Generic Letter 95-09, " Monitoring and Training of Shippers and Carriers of

Radioactive Materials," states that in order to avoid imposing the cumbersome and

costly requirements of having to provide radiation monitoring and radiation safety

instruction to all employees of carrier companies that enter the licensee's restricted

area, the licensee may request a letter from the carrier certifying that their personnel

are trained and monitored in accordance with the requirements of applicable section

of 10 CFR Pans 19 and 20.

In response to the generic letter, the licensee had initiated a practice of escorting

shippers or carriers through the radiological controlled areas as the means to meet

the intent of a program for monitoring and training of shippers and carriers of

radioactive active material. The inspectors agreed that this sufficed as an

appropriate means of protecting these people from potential radiological hazards,

but stated that it would be discussed with NRC personnel from the responsible

program office. NRC headquarters personnel confirmed that this was an

acceptable approach,

c. Conclusions

All workers participating in the preparation and packaging of radioactive materials

and radioactive waste were appropriately trained.

R6 Radiological Protection and Chemistry Organization and Administration

The inspectors determined that the organization and staffing of the licensee's

radiation protection department was adequate to implement tha radioactive waste

and transportation programs.

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! R7 Quality Assurance in Radiological Protection and Chemistry Activities

j a. Insoection Scope (86750) -

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The inspectors reviewed quality assurance audits performed by, or for the licensee. J

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l b. Observations and Findinas I

' The inspectors noted that, although the 1996 audit by the Nuclear Overview

Department reviewed iadioactive waste issues, it did not comprehensively review

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transportation activities. Instead, the licensee took credit for an assessment

performed by a contractor. The contractor assessment was very thorough and it

l was performed by technical experts. The assessment provided suggestions for

i improvement and assurance that the necessary programs and procedural guidance

l were in place. The licensee had addressed and corrected the independent

} assessment findings with potential regulatory bases. The remaining open items

! were determined by the inspectors to be enhancements to the transportation

program. I

l The contractor assessment was performed before any shipments were made in

j accordance with the revised transportation requirements. The inspectors

determined that no oversight activities had been conducted since the revised

. transportation regulations were implemented to confirm regulatory compliance. In l

l response to the inspectors comments concerning overview of transportation

j activities, Nuclear Overview Division personnel stated that previous reviews of the

i . transportation program identified few problems; therefore, this area needed less

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oversight. There are no regulatory requirements mandating an independent

assessment prior to communcing the revised transportation activities,

c. Conclusions

j An excellent assessment was performed by a contractor of the solid waste

management and transportation activities; however, the licensee had not verified

j through oversight activities that the revisions to transportation regulations were

] implemented correctly,

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! R8 Miscellaneous Radiological Protection and Chemistry issues

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i The inspectors reviewed the guidance in Radiation Protection Instruction 213,

" Survey and Release of Material and Personnel," Revision 6, and discussed the '

", unconditional release of items from the radiological controlled area with radiation

j protection technicians. The inspectors determined that practices met the guidance

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in Information Notice 85-92, " Surveys of Wastes Before Disposal From Nuclear

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Reactor Facilities."

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. The inspectors asked about the disposal of sewer sludge, an issue discussed in

. Information Notice 88-22, " Disposal Of Sludge From Onsite Sewage Treatment

. Facilities At Nuclear Power Stations." The inspectors determined that the licensee

i identified small amounts of cobalt contamination in sewage sludge from the onsite ,

I sewage treatment plant. Licensee representatives stated that the sludge was being l

stored on site until a suitable solution to the problem of disposal is found.

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! V. Manaaement Meetinos

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i X1 Exit Meeting Summary i

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The inspectors presented the results of the inspection to members of licensee '

j management at the conclusion of the inspection on April 10,1997. The licensee

i acknowledged the findings presented. No proprietary information was identified.

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ATTACHMENT

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SUPPLEMENTAL IfGORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

j J. Ayres, Plant Support Overview Manager

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A. Barnette, Radiation Protection Supervisor  ;

. S. Bradley, Radiation Protection Supervisor l

l R. Carr, Radiation Protection Supervisor

J. Curtis, Radiation Protection Manager

T. Edwards, Radwaste Engineering Technician

R. Fishencord, Radiation Protection Supervisor

. L. Hughes-Edwards, Radwaste Operations Supervisor

D. Kay, Radiation Protection Supervisor

R. Knapp, Senior Health Physicist j

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J. Luna, Radiation Protection Technician 1

G. Millican, Radiation Protection Lead Technician {

C. Welch, Senior Nuclear Specialist, Nuciear Overvievi l

C. Wilkerson, Senior Engineer, Regulatory Affairs  !

4 NRC

H. Freeman, Resident inspector

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INSPECTION PROCEDURES USED

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Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive

Materials

COCUMENTS REVIEWED

Quality Assurance

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NOE-EVAL-96-000141 Radwaste and Effluent / Environmental Monitoring Program,

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September 12,1996

NOE-EVAL-96-000026 Radioactive Waste Packaging and Shipping, April 2,1996

WMG Report 9608 Radioactive Material Management Practice Assessment at the

Comanche Peak Nuclear Plant, July 1996

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Procedures

STA-652 Radioactive Material Control, Revision 7

STA-709 Radioactive Waste Management Program, Revision 6

RPI-213 Survey and Release of Material and Personnel, Revision 6

RPI-215 Waste Stream Sampling, Revision 1

RPI-230 Radioactive Material Shipments, Revision 1

RPI-232 Characterizing Radioactive Material for Shipment, Revision 2 i

RPI-255 Characterizing Radioactive Waste for Disposal, Revision 2

RPI-256 Radioactive Waste Classification for Disposal at the Barnwell Waste

Management Facil%, Revision 2

RPI-260 Radwaste Container Tracking and Accountability, Revision 2 l

Other

Annual Radioactive Effluent Release Report, January 1 - December 31,1996

Radiation Protection Department Organization Charts

Radwaste Container Inventory

Training Program and Records  !

Radioactive Materials Shipping Logs for 1995 and 1996

ONE Forms96-842,96-1472,96-922, 96-991, 96-1546,96-674

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