IR 05000498/1997017

Insp Repts 50-498/97-17 & 50-499/97-17 on 970714-17.No Violations Noted.Major Areas Inspected:Plant Support

ML20198G059
Person / Time
Site:	South Texas
Issue date:	08/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198G028	List: IR 05000498/1997017 ML20198G020
References
50-498-97-17, 50-499-97-17, NUDOCS 9708130271
Download: ML20198G059 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No ;50 499 License Nos.: NPF-76; NPF-80

, Report No.: 50 498/97 17;50 499/97 17 l

Licensee: Houston Lighting & Power Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 8 miles west of Wadsworth Wadsworth, Texas Dates: July 14-17,1997 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENT: Supplemental Information

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9708130271 970808 PDR ADOCK 05000498 G PDR

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EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50 498/97 17;50 499/97 17 This announced, routine inspection reviewed the implementation of the solid radioactive waste management and the radioactive waste and materials transportation program Training, procedural guidance, and quality assurance oversight were also reviewe >

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A good solid radioactive waste management program was implemented. The licenseo effectively reduced the volume and radioactivity of solid radioactive waste generated (Section R1.1).

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Waste streams were properly sampled and analyzed. Solid radioactive waste was

properly classified and characterized for shipment and disposal (Section R1.1).

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A good transportation program for radioactive materials and radioactive waste. was maintained. Shipments of radioactive materials were made consistent with the latest revisions to the Department of Transportation and NRC regulations (Section R1.2).

Proper programmatic controls and procedures for handling, processing, and shipping of radioactive waste / materials were implemented. The procedure for shipping low l

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specific activity materials and surface contaminated objects was consistent with regulatory requirements (Section R3).

The health physics division and radiological services team were adequately staffed with knowledgeable and experienced personnel who were properly trained and qualified (Section R4).

The training program properly addressed the revisions to the transportation regulations. All personnel participating in the preparation and packaging of radioaceve waste and radioactive materials were appropriately trained (Section RS).

The inspector determined that proper staffing was maintained to implement the solid radwaste and transportation programs. The licensee's staff responsible for implementing the solid radwaste and transportation programs had experienceu little change and no reduction during the past 1 % years (Section R6).

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• An effective quality assurance program was maintained. Comprehensive annual audits of the radioactive waste management and transportation programs were performed. Only one quality assurance radioactive waste operational surveillance was performed since January 1990. Condition reports related to radioactive waste activities were closed in a timely manner (Section R7).

• The inspector noted that the lead quality assurance auditor assigned to oversee solid radioactive waste and transportation program activities had a limited i

radioactive weste background. However, technical specialists knowledgeable in radioactiva waste management and transportation requirements were members of the audit teams (Section R7h

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B9n9tLDJt1Aile Ruminaty_qLannt status Units 1 and 2 were at full power during this inspection. No events occurred during this inspection that adversely affected the inspection result IV PlanLS3mnett R1 Radiological Protection and Chemistry Controls R Solid Ra lioactive Waste Mananoment Jngoection Scope (Tl 2515/133 and 86750)

The inspector interviewed members of the health physics division and the radiological services team and observed or reviewed the following solid radioactive waste management program activities:

• Container storage and labeling

• Container accountability

• Radioactive waste storage areas

• Waste stream sampling results and waste characterization documentation

• Scaling f actors for required isotopes not measured directly

• Solid radioactive waste classification

• Sluicing of spent resin into a high integrity container

• Quantities of radioactive waste shipped for disposal

• Waste minimization program

• Annual radioactive effluent and solid radioactive waste reports Observation 1 and Findinns The inspector toured areas in each unit where radioactive waste / materials were handled, stored, and processed. Containers of radioactive waste and radioactive materials were properly labeled and stored. The radioactive waste processing and storage areas in both units were well maintained. The inventory of packaged radioactive waste and radioactivo materials was properly controlled and accountability was maintained. The inspector verified that radioactive waste was properly classified and characterized. Housekeeping in the radioactive waste processing and storage areas was good.

l Through record reviews, the inspector verified that radioactive waste stream sampling and analyses was performed as required during 1995 and 1990. The licensco used a vendor laboratory for analysis of the identified waste stream Scahng f actors were computed to account for isotopes that were not easily detected and for required nongamma emitting nuclides. The licensee's computer i

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5-program data base was updated routinely with the latest waste stream analysis results. The inspector reviewed the method by which the licensee entered new scaling f actor information into the radioactive waste computer program data bas The data was reviewed and no discrepancies were note On July 15,1997, the inspector attended the pre job briefing prior to the sluicing of spent resin from the low activity spent resin storage tank to a high integrity container in the Unit 2 truck bay. During the pre job briefing, job activities and personnel assignments were appropriately discussed, including radiation surveys and radiation posting requirements. Continuous health physics coverage was observed in the truck bay during the sluicing of the resin. Proper control and posting of a high radiation area in the truck bay was established. The sluicing of the resin was performed according to approved procedures with minimal radiation exposure to the worker The volume and activity of solid radioactive waste including resins, filters, irradiated components, and dry active waste shipped for disposal during the past G years is tabulated below. This data indicates solid radioactive wasa shipped, not buried; therefore, the data does not show any volume reduction due to incineration,

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Reran and Filters Dry Active Waste Total Volume Activity Volume Activity Volume Activity Year (ft') (Ci) (ft') (Ci) (ft') (Ci)

1992 ?.02 .4 17,43 .720 19.45 .1 1993 1,00 ,30 ,12 .722 -30.12 ,30 ,78 .7 10,40 .689 12,18 .4 1995 99 .32 15,74 .334 16,73 .7 1996 1,08 ,42 10,40 .638 11,48 .1 In 1993, a majority of the dry active waste shipped for processing was generated during the 1992 Refueling Outage 1RE04, and most of the total activity shipped, 5,878 cuiss, was from an irradiated hardware shipment of bottom mounted instrumentation. thimble tubes. The increased volume of dry active waste shipped in 1995 was a result of Refueling Outages 1RE05 and 2RE04 Over the past 5 years, the inspector noted a trend of decreasing total volume and curies of radioactive waste shipped for disposal. The inspector confirmed, through document reviews and personnel interviews, that the licensee had implemented an effective solid radioactive waste reduction program. During

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6-Refueling Outages 2RE05 and 1RE06, the solid radioactive waste production volume goals of s 2500 cubic feet of dry active waste and s 125 cubic feet of radioactive filters were met. Since 1992, the total annual volume of solid radioactive waste generated has been toduced by approximately 40 percen ConclusiQrl)

A good solid radioactive waste management program was implemented, which reduced the volume and radioactivity of solid radioactive waste generated and maintained accountability for containers of solid radioactive waste and material Waste stream sampling and analysis met procedural and regulatory requirement Solid radioactive waste was properly classified and characterized for shipment and disposa R1.2 Transportation of Radiep_qtive Materials and Radioactive Waste

_ IDIDE1 LED _h0pe fTI 2515/133 and 86750)

The inspector interviewed radiological services team personnel and reviewed the following:

• Implementation of revised 49 CFR Parts 100179 and 10 CFR Part 71

• Shipping documentation from selected shipments (April 1996 to June 1997)

• Certificates of compliance for NRC certified shipping casks

• Department of Transportation and NRC regulations and state licenses

• Licenses for tecipients of radioactive wastes and/or materials

• Marking and labeling of packages

• Vehicle placarding and driver instructions

• Emergency response information

• Radiation surveys of packages and vehicles

• Packaging and shipping papers

• Use of system international units

• Use of the current A i /A, values

• Computer program used to generate shipping papers Qbuty.g1[qns and Findinns No shipments of radioactive wastes or radioactive materials were made during the week of inspection; therefore, no observationn et actual shipment preparation were possible.

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! A vendor supplied computer code was used to deterrnine proper radioactive material i transportation categories, shipping packages, labeling, and to generate shipping l papers. Procedures for manual methods were available as a backup. The inspector-reviewed the isotope library file of the computer program and confirmed that the

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latest A, and A, values for selected isotopes, from 49 CFR 173.435, had been i- entered and were being used.

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The inspector reviewed selected shipping documentation for shipments of radioactive waste and/or materials made from the station after April 1, J

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1990, to determine compliance with the revised Department of Transportation and NRC regulations for shipments. The inspector verified that shipments complied with 49 CFR Part 172, Subpart C,10 CFR Part 20, Appendix F,49 CFR 173.433,-

and 49 CFR 173.435. Shipping documents in

luded radioactive source activity measurernents recorded in international system units, as well as, customary units required af ter April 1,1997, on packaging and shipping documentatio .

Photographs of radioactive waste shipments confirmed that shipments were

' properly labeled, marked, and placarded. Radiation survey records indicated tha radiation and contamination levels of shipments were within regulatory limits.

Emergency telephone numbers included with the shipping papers were current.

The inspector verified that the licensee maintained current copies of applicable certificates of compliance for NRC approved shipping casks; Department of Transportation, NRC, and the competent state authority regulations,-appropriate

state licenses, and state transportation permits; and copies of current licenses for j recipients of shipments of radioactive wastes and/or materials. This was consistent

with the licerssee's commitmentw to inspection and Enforcement Bulletin 7919.

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! c. Conclusions l- A good transportation program for radioactive materials and radioactive waste was maintained. Packages were properly prepared for shipment. Current Ai and A, 4 values were being used to characterize shipments in accordance with transportation regulations. Shipments of radioactive materials were made consistent with the latest revisions to the Department of Transportation and NRC regulation R2 Status of Facilities and Equipment The inspector toured the radwaste areas in both units and determined that the f acilities including, the advanced liquid processing system installed in each unit's truck bay, were as described in the updated final safety analysis repor , . .. _

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R3l : Procedures _ and Documentation .

a,- Insoection Scooe (Tl 2515/133 and 86750F I

- The inspector reviewed the following:-

Procedures listed in attachment i

• The licensee's process for shipments of fissile material

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~ Observations and Findiaqn Procedures OPRPO3 ZR 0002, " Radioactive Waste Shipments," Revisl6n 9, and

- OPRF03 ZR 0011, " Shipment of Radioactive Materials," Revision 3, addressed-revisions in shipping regulatory requirements, such as, the division of the low -

, -specific activity category into subcategbries, the introduction of the surface l ,contarrAriated object category, the use of international system units for activities and radiation measurements on shipping papers, and the classification of fissile

materia The licensee's shipping prdcedures were detailed and provided clear guidance. The: -

procedures indicated the order in which to perform the major steps in preparing radioactive waste or radioactive materials for shipment. The steps referenced applicable regulatory requirements. Attachments included stepwise instructions and

- additional regulatory references, specific to the different transportation categories.-

The licensee had made shipments of radioactive materials classified as surface contaminated objects,'The licensee's procedures addressed how the astiassment of-contaminated surfaces for inaccessible areas was to be accomplished, Conclusions

, Programmatic controls and procedures for handling, processing, and shipment of radioactive waste / materials were properly implemented. The procedure for shipping low specific activity materials and surface contaminated objects was consistent with regulatory requirement R4 - Staff Knowledge and Performance a.- Inspectibn Scone (Tl 2515/133_and '86750)

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The inspector interviewed members of the health physics division and the 0 iiological services team,

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- Observations and Findinns

Through _ interviews and discussions, the inspector determined that the personnel l responsible for conducting the transportation program for radioactive waste and '

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radioactive materials were knowledgeable of currently revised transportation

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regulatory requirements which were effective April 1,1996,'and April 1,199 .

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lThe health physics division and radiological services team were adequately staffed -

with knowledgeable and experienced personnel who were properly trained and qualifie R5' ~ Staff Training and Qualification

, hisoection Scope (Tl 2515/133 and 86750)

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Ttje inspector reviewed the periodic trainirig of personnel who were responsible for - '

the preparation and packeging of radioactive waste and radioactive materials for shipment. Also, the inspector reviewed the actions the licensee had taken_ in response to Generlo Letter 95-0 The inspector reviewed the following:

• Training materials related to 49 CFR Parts 171179 and 10 CFR Part 71

• Training and qualification records of personnel performing radioactive waste and radioactive materials shipmei..a Observations and Findingg The inspector verified that personnel participating in the preparation of radioactive

. waste radioactive materials shipments had periodic retraining within the previous 2 years and were trained on transportation regulation revisions prior to-implernentation of the new regulatory requirements effective April 1,199 Retraining on the implementation of the 1996 radioactive transport regulations and operation of the computer program used to classify radioactive waste for burial and p to prepare radioactive material packages for transport was provided by a contractor .

in July 199 The inspector verified that radwaste personnel including health physics technicians, deconners, and station operators were appropriately trained. The health physics technicians and radiological services team personnel demonstrated a thorough kr ;wledge of the revised transportation regulation l

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The inspector verified that the licensee implemented guidance in Generic Letter 95 09, " Monitoring and Training of Shippers and Carriers of Radioactive Materials,"

regarding employees of carrier companies that enter the licensee's restricted are The licensee's shipping procedures addressed the requirement for a training program and a radiation protection program for shippers ano carriers and provided guidance in an addendum and checklist to the procedures to monitor this new requiremen .

c. Conclusions The training program properly addressed the revisions to the transportation regulations. All personnel participating in the preparation and packaging of radioactive waste and radioactive materials were appropriately traine R6 Rediological Protection and Chemistry Oiganization and Administration I

a. Insoection Scoce (8675Q1 The health physics division organization and staffing for the solid radioactive waste management program and the transportation program for radioactive waste and radioactive materials were reviewed, b. Qhservations and Findinas Since the last inspection of the solid radioactive waste program, the organizational alignment for the solid waste program changed significantly. A new group called -

the radiological services team was created within the health physics division. The inspector verified that the health physics division and radiological service: team personnel were responsible for the implementation of the solid radioactive waste management program and transportation of radioactive waste and radioactive materials program. Two radiation protection technicians assigned to the radiological services team were primarily responsible for the preparation of radioactive waste and radioactive materials for shipment. The inspector determined that the duties and responsibilities for implementing the solid radioactive waste management program and the transportation program for radioactive waste and radioactive materials were being properly implemente The organization and staffing of the health physics division and the radiological services-team wero edequate to implement the solid radioactive waste management program and transportation program for radioactive waste and radioactive material There had been two personnel changes in the staff directly responsible for the management and implementation of the solid radioactive waste and transportation programs during the past 1 % years. These changes included the radwaste health physicist and the radiological services team supervisor. The radiation protection technicians assigned to the solid radioactive waste management program had not changed and provided continuity and experience, s _

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4:7-1 1 - Conclusiong

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The inspector determined that proper staffing was maintained to implement the solid-radweste and transportation programs. The licensees staff responsible for implementing the solid radwaste and transportation program had experienced little change and no reduction during the~past 1 % year R 7_ . Quality' Assurance in Radiological Protection and Chemistry

- Activities Inspection Scooe (86750)

The lead auditor involved _with the performance of quality assurance audits and

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surveillances of the solid radioactive waste mancgement and transportation of radioactive materials programs was interviewed. The following items were-  ;

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Qualifications and resumes of auditors and technical specialists

Quality assurance audits performed since January 1996

Quality assurance surveillances performed since January 1996

Quality assurance monitoring reports since January 1996

Radiological condition reports writton since January 1996 Observations and Findinos The inspector reviewed the quailfications of the lead quality assurance auditor-assigned to oversee health physics division activities. The inspector noted that this individual had a number of years of auditing experience but a limited background in- a health physics and especially in radioactive waste management. During discussions with quality assurance personnel, the inspector was informed that the' lead quality assurance radiation protection. auditor had qualified as a junior radiation protection technician and had supported the health physics division during recent outages,- 1

- Additionally, vendor supplied radiation protection courses and radioactive waste management and radioactive waste disposal ccurses_were scheduled to enhance this individual's knowledge of the radiation protection program and the radioactive waste management program and current regulatory requirements. The 1996 and

'1997 quality assurance audits of the radiological controls and radioactive waste

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management programs were performed using a technical specialist who had experience in the radioactive' waste management program are The inspector reviewed the 1996 and 1997 radwaste audits and determined that the audits were comprehensive and provided a thorough overview of the radioactive waste management and transportation programs. The audits identified deficiencies and recommendations in the radioactive waste program area. .The deficiencies were-tracked by_the licensee's condition reporting system, which was used to track corrective actions. The inspector reviewed the corrective actions and determined

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h that they were appropriate to correct the deficiencies identified. The inspector noted that these items were closed in a timely manne '

'Only 1 quality assurance radioactive waste surveillance w'as performed since January :16 25,1996. However,17 quality monitoring reports (field observations) .

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were written. No problems were identified with the report The health p5t ysics division wds perfSrming a pr~ogram based self assessment of the

radioactive waste management 'and transportation program '

No negative trends were identified during the review of radiological condition repo.rts of the radioactive waste program area. The inspector noted that recommendations to prevent a recurrence appeared to be appropriate and corrective-actions were closed in a timely manne Conclusions An effective quality assurance program was maintained. Comprehensive anr,ual audits of the radioactive waste _ management _ and transportation programs were /

performed. The inspector note.d that the_ lead quality assurance auditor assigned to oversee solid radioactive waste and transportation program activities had a limited radioactive waste background. . However, technical specialists knowledgeable in radioactive wute management and transportation' requirements were members of the audit teams.- Only one quality assurance radioactive waste operational surveillance was performed since January 1996. -Condition reports related to

. radioactive waste activities were closed in a timely manner. Effective quality assurance audits,-surveillances, and monitoring reports of the radioactive waste management and transportation program activities provided were indicative of good -

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management oversigh V. Manaaement Meetinos X1 Exit Meeting Summary

, The inspector presented the inspection.results to members of licensee's management at an exit meeting on July 17,1997. The licensee acknowledged the

< findings presented. No proprietary information was identifie .

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ATTACHMENI SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED -

Licenste ..

M.' Domal, Health Physicist B. Dowdy, Manager, Unit 2 Operations;-

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A. Granger, Administrator, Nuclear Safety Evaluations W. Harrison, Senior Consulting Engineer, Licensing

-- S. Head, Senior Consulting Engineer, Licensing J. Inman,-Health Physics Specialist

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K. Kleinhans, Radiation Protection Technician T. Koser, Staff Engineering Specialist, Licensing R. Logan, Manager, Radiation Protection .

M. Markovich, Senior Specialist, Quality Assurance  !

L. Martin, General Manager, Nuclear Assurance and Licensing

B. Mookhock, Staff Engineer, Licensing

- G. Parkey, Plant Manager, Unit 1 J. Sherwood, Radiation Protection Supervisor

- S. Smith, Specialist, Quality Assurance W. Smith, Radiation Protection-Technician P. Walker, Staff Engineer, Licensing NBC L D.-Loveless, Senior Resident inspector INSPECTION PROCEDURES USED f - 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 LIST OF DOCUMENTS REVIEWED ,

ORGANIZATION CHART Radiation Protection Organization Chart July 1997-

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.QUALITY ASSURANC1,QQQ_UMENTS

- OPOPO1 ZA 0001, " Plant Audits," Revision 1 -

OPOP01 ZA;0015, " Oversight Planning and Scheduling Process," Revision 4 Quality Assyrance Audits

' Quality. Audit Report 9610, " Radiological Controls /Radwaste " January 9,1997 Quality _ Audit Report 97 03, " Radiological Controls /Radwaste," April 21,1997

- Quality Assurance Surveillance Quality Surveillance Report 96 005, " Radioactive Waste Material Shipping,"

February 12,1996 Quality' Assurance Monitorino Reports -

Quality _ Monitoring Report MN-96-2-0030, "Radwaste Shipment of Tri Nuc Filte s,"

January 16,1996 Quality Monitoring Report MN 96 2 0154, " Preparations for a Class B Radioactive Shipment,"_ March 7,1996

' Quality Monitoring Report MN-96-10245, "High Integrity Container of Resin Transfer,"

April 15,1996 Quality Monitoring Report MN 96-1-0406, "Radweste Minimization Activities,"

May 22,1996 Quality Monitoring Report MN-96-1-0407, "Radwaste Minimization Activities,"

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-Quality Monitoring Report MN-96 0-0558, "High Integrity Container and Shielded Storage Container Transferred," June 3,1996-Quality Monitoring Report MN 96-10627, "Radwaste Minimization Activities,"

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- Quality Monitoring Report MN-96-0-0701, " Preparation of a Special Radwaste Shipment,"

' July 9,1996 Quality _ Monitoring Report MN-96 0-0745, " Preparation of a Shipment of Radioactive f Materials,"; July 23,1996

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g- ~y 3-Quality Monitoring Report MN-96 2 0855, " Resin Shipment STP-2-96-0054,"

- October 16,1996 Quality Monitoring Report MN 96 2-0855, " Resin Shipment STP 2 96-0054,"

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Quality Monitoring Report MN 96-0 0917,' " Dry Active Waste Shipment STP-0-96-0063,"

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November 25,1996 Quality Monitoring Report MN 96-0-0924,-" Followup on Quality Assurance Audit 9610 Findings," December 3,1996 Quality Monitoring Report MN-96 0-0925, " Followup on Quality Assurance Audit 96-10

- Findings," December 4,1996

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Quality Monitoring Report MN 97-0-0466, " Review of Shipment Manifest 72556,"

April 9,- 1997-Quality Monitoring Report MN 97 2-0518, " Pre-job Briefing for Radwaste Shipment of -

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.Tri Nuke Filters," May 6,1997 Quality Monitoring Report MN 97-1-0520,'" Pre-job Briefing.for Sealing and Weighing a High Integrity Container," May 13,1997 Quality Monitoring Report MN 9710521, " Pre-job Briefing for Moving a High Integrity-

Container," May 14,1997-

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Quality Monitoring Report MN 971-0553, " Pre-job Briefing for Radwaste Resin Shipment STP_1-97-0033," June 11,1997

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PROCEDURES OPGP03-ZO 0017,'" Radioactive Waste Process Control Program," Revision 3 L OPGP03 ZR 0053, " Radioactive Material Control Program," Revision 3 OPRPO3 ZR-0001, " Determination of Radioactive Material Curie Content, Reportability,- ',

DOT Sub Type and Waste Classification," Revision 5 -

OPRP03-ZR-0002, " Radioactive Waste Shipments," Revision 9--

OPRP03-ZR 0009, "10 CFR Part 61 Sampling and' Analysis Program," Revision 2 OPRP03 ZR-0010,." Dry Active Waste Operation," Revision 5 OPRPO3-ZR-0011, " Shipment of Radioactive Material," Revision 3 i

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-4 OPRP03 ZR 0012, " Tracking and Loading of Spent Radioactive Filters into High Integrity Containerss" Revision 2'

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OPRP07-ZR 0009, " Performance of High Exposure Work," Revision 8 0 POP 02 WL-0028, " Wet Solid Radioactive Waste Processing," Revision 4 BgPORTS Annual Radioactive Effluent Release Reports 1995 and 1996

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MISCELLANEOUS DOCUMENIH Summary of Radwaste Condition Reports written since January 1996 Radiation Work Permit 1997-0-0141, Revision 0, " Plant Walkdown, Tours and Inspections"

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