ML20148B589
| 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: |
| References | |
| 50-445-97-11, 50-446-97-11, NUDOCS 9705130161 | |
| Download: ML20148B589 (9) | |
See also: IR 05000445/1997011
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ENCLOSURE
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Docket Nos.:
50-445
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50-446
License Nos.:
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Report No.:
50-445/97-11
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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:
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
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.
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Plant Sucoort
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The solid waste management program was implemented well (Section R1.1).
The licensee implemented the transportation regulation revisions properly. A good
program for the transportation of radioactive materials and radioactive waste was
maintained (Section R1.2).
The licensee's procedures were very detailed and provided clear guidance. The
transportation procedures implemented the revisions of 49 CFR (Section R3).
The individuals responsible for conducting the radioactiv'e waste transportation
program activities were knowledgeable of regulatory requirements and software
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utilization constraints (Section R4).
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All workers participating in the preparation and packaging of radioactive materials
and radioactive waste were appropriately trained (Section R5).
The organization and staffing of the licensee's radiation protection department was
appropriate to im 'oment the radioactive waste and transportation programs
(Section R6).
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
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characterization of radioactive waste streams.
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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
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.
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The transportation procedures had been revised to implement the revisions of
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49 CFR. However, there were minor examples in which additional revisions were
.needed, because the procedures included the errors originally published in the
Federal Reaister. - None of the errors were significant enough to adversely affect
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the licensee's radioactive materials transportation program. The licensee promptly
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initiated the required revisions to the procedures.
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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
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
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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
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a.
Insoection Scope (86750)
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The inspectors reviewed quality assurance audits performed by, or for the licensee.
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b.
Observations and Findinas
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The inspectors noted that, although the 1996 audit by the Nuclear Overview
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Department reviewed iadioactive waste issues, it did not comprehensively review
transportation activities. Instead, the licensee took credit for an assessment
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performed by a contractor. The contractor assessment was very thorough and it
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was performed by technical experts. The assessment provided suggestions for
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improvement and assurance that the necessary programs and procedural guidance
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were in place. The licensee had addressed and corrected the independent
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assessment findings with potential regulatory bases. The remaining open items
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were determined by the inspectors to be enhancements to the transportation
program.
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The contractor assessment was performed before any shipments were made in
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accordance with the revised transportation requirements. The inspectors
determined that no oversight activities had been conducted since the revised
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transportation regulations were implemented to confirm regulatory compliance. In
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response to the inspectors comments concerning overview of transportation
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activities, Nuclear Overview Division personnel stated that previous reviews of the
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. 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
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An excellent assessment was performed by a contractor of the solid waste
management and transportation activities; however, the licensee had not verified
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through oversight activities that the revisions to transportation regulations were
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implemented correctly,
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R8
Miscellaneous Radiological Protection and Chemistry issues
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The inspectors reviewed the guidance in Radiation Protection Instruction 213,
" Survey and Release of Material and Personnel," Revision 6, and discussed the
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unconditional release of items from the radiological controlled area with radiation
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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
Reactor Facilities."
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The inspectors asked about the disposal of sewer sludge, an issue discussed in
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Information Notice 88-22, " Disposal Of Sludge From Onsite Sewage Treatment
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Facilities At Nuclear Power Stations." The inspectors determined that the licensee
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identified small amounts of cobalt contamination in sewage sludge from the onsite
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sewage treatment plant. Licensee representatives stated that the sludge was being
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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Exit Meeting Summary
The inspectors presented the results of the inspection to members of licensee
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management at the conclusion of the inspection on April 10,1997. The licensee
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acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT
SUPPLEMENTAL IfGORMATION
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
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J. Ayres, Plant Support Overview Manager
A. Barnette, Radiation Protection Supervisor
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S. Bradley, Radiation Protection Supervisor
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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
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D. Kay, Radiation Protection Supervisor
R. Knapp, Senior Health Physicist
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J. Luna, Radiation Protection Technician
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G. Millican, Radiation Protection Lead Technician
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C. Welch, Senior Nuclear Specialist, Nuciear Overvievi
C. Wilkerson, Senior Engineer, Regulatory Affairs
NRC
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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
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,
September 12,1996
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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
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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
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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