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Insp Rept 50-458/86-22 on 860630-0703.Violation Noted: Licensee Shipment on 860519 of 70 Mci Spent Resins Solidified in Cement to Chem-Nuclear Sys,Inc Received w/3.7% Free Standing Liquid within Liner
	ML20206N378
Person / Time
Site:	River Bend
Issue date:	08/11/1986
From:	Baer R, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20206N366	List: ML20206N361; ML20206N368; ML20206N373; ML20206N378;
References
	50-458-86-22, NUDOCS 8608260244
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APPENDIX C

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-458/86-22 License: NPF-47

Docket: 50-458

Licensee: Gulf States Utilities (GSU)

P. O. Box 220

St. Francisville, Louisiana 70775

Facility Name: River Bend Station (RBS)

Inspection At: RBS, St. Francisville, Louisiana

Inspection Conducted: June 30 through July 3,1986

Inspector: J - d [M

R6 E. Baer, Radiation Specialist, Facilities Date

Radiological Protection Section

Approved: M 4_/ #

Biaine Murray, Chieft Facilities Radiological Date

Protection Section

Inspection Summary

Inspection Conducted June 30 through July 3,1986 (Report 50-458/86-22)

Areas Inspected: Routine, unannounced inspection of the licensee's solid

radioactive waste and transportation activities program including:

organization and management controls, training and qualifications, low-level

radioactive waste storage, audits, transportation activities, and solid waste

management.

Results: Within the area inspected, one violation and one deviation were

identified (see paragraphs 6 and 9).

8608260244 860820

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DETAILS

1. Persons Contacted

GSU

W. J. Cahill, Jr., Senior Vice President

J. C. Deddens, Vice President, River Bend Nuclear Group

T. F. Plunket Plant Manager

T. P. Anthony, Senior Mechanical Engineer

R. E. Bailey, Supervisor, Quality Control

J. P. Bleau, Radwaste Specialist

L. N. Campo, Radwaste Specialist

E. M. Cargill, Supervisor, Radiological Programs

J. W. Cook, Environmental Analyst

^*T. C. Crouse, Manager, Quality Assurance (QA)

S. Desai, Chemical Process Engineer

R. G. Easlick, Radwaste Supervisor

D. R. Gipson, Assistant Plant Manager, Operations

B. R. Hall, Plant Service Supervisor

K. C. Hodges, Supervisor, Quality Engineer

R. J. King, Licensing Engineer

J. M. McGhee, Radwaste Foreman

C. L. Nash, Chemistry Supervisor

K. Ormstedt, QA Engineer

E. R. Oswood, Senior QA Engineer

K. E. Suhrke, Manager Projects, Planning

P. F. Tomlinson, Director, Quality Services

M. E. Walton, Technical Assistant

Others

D. K. Carner, Solidification Technician, Chem-Nuclear

D. J.-Jeffrey, Solidification Technician, Chem-Nuclear

D. D. Chamberlain, Senior Resident Inspector, NRC

W. B.' Jones, Resident Inspector, NRC

The NRC inspector also interviewed several other licensee and contractor

employees.

Denotes those individuals present during the exit interview on July 3,

1986.

2. Inspector Observations

The following is an observation the NRC inspector discussed with the

licensee during the exit interview on July 3, 1986. This observation is

neither a violation nor unresolved item. This item was recommended for

licensee consideration for program improvement, but it has no specific

regulatory requirement. The licensee stated this item would be reviewed.

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- Radioactive Waste Segregation' Program - The licensee had not implemented a

radioactive vaste segregation program. See paragraph 9 for additional

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details.

3. Organizat' ion and Management Controls

The NRC inspector reviewed this licensee's staff functional assignments

relating to solid radioactive waste and transportation activity

organization and management controls for compliance with Inspection and

Enforcement (IE)Bulletin 79-19, Technical Specification (TS) 6.2 and

commitments in Section 13.1.2.1.1 of the Final Safety Analyses

Report (FSAR).

The licensee had not issued the GSU Radioactive Waste. Management Policy

Statement (RWMPS) at the time this inspection commenced. This issue had

been addressed in NRC Inspection Report 50-458/85-82, at which time the

licensee stated the RWMPS had not been issued because of some ninor

changes that needed to be addressed. The NRC inspector discussed with

licensee representatives the delay in the issuance of the RWMPS and that

procedure ADM-0038, " Radioactive Waste Management Program," Revision 3,

May 29, 1986, Attachment 1 contains a RWMPS which would lead an individual

to believe this statement had been issued. As a result of these

discussiens, the licensee issued the RWMPS on July 3, 1986.

The NRC inspector expressed concern and discussed with licensee

representatives the apparent lack of management commitment to the

radioactive waste management program. The licensee indicated that they

would review the inspector's concern.

No violations or deviations were identified.

4. Training and Qualifications

The NRC inspector reviewed the licensee's training program for personnel

involved in solid radioactive waste activities and transportation of

radioactive materials to determine compliance with this requirement of

IE Lulletin 79-19, TS 6.4 and commitments in Section 13.2 of the FSAR.

The NRC inspector reviewed the qualifications and training for personnel

responsible for radioactive material transportation-activities and

reviewed the regulatory awareness training program which personnel are

required to attend.

The NRC inspector noted that the radwaste supervisor maintains a roster of

radwaste qualified radiation protection technicians to ensure that those

persons performing transportation activities are qualified by training.

Procedure RWS-0203, " Personnel Qualifications for Radwaste Section,"

contains the qualification requirements for all personnel assigned to the

radioactive waste management organization and support personnel who perform

transportation activities.

No violaticns or deviations were identified.

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5. Low-Level Radioactive Waste Storage Facility

The1TRC inspector reviewed the status of the low-level radioactive

waste (LLRW) storage facility for compliance with the facility license

conditions and the recommendations of NRC Generic Letter 81-38,

NRC IE Circular 80-18, NRC Regulatory Guide (RG) 1.143 and NUREG-0800.

The licensee had not constructed, or planned for the construction of a

LLRW storage facility. Section 11.4.2.7 of the final safety analysis

report addresses the storage capacities for reactor operations.

No violations or deviations were identified.

6. Waste Generator Requirements 10 CFR 20 and 10 CFR 61

The NRC inspector reviewed the licensee's program for disposal of LLRW to

determine compliance with the requirements of 10 CFR Parts 20.311, 61.55,

and 61.56.

The licensee presently uses scaling factors as described in the procedure

" Methodologies for Classification of Low-Level Radioactive Waste from

Nuclear Power Plants," issued by the Atomic Industrial Forum. The

licensee had issued a purchase requisition for a vendor to provide for the

determination of sample locations and for the analysis of samples to meet

the requirements of 10.CFR Part 61.

On May 19, 1986,, Gulf States Utilities shipped 70 millicuries of byproduct

material, designated as Low Specific Activity (LSA), in the form of solid

metal oxides on resin solidified in cement.- The shipment was made by a

Common Carrier on a tractor-trailer containing two type 14-195 liners. On

May 23, 1986, a representative of the South Carolina Department of Health

and Environmental Control inspected the shipment. The inspection

consisted of a review of shipping papers, placarding, marking and

labeling, radiation measurements, selective contamination surveys, and

examination of the packages and the vehicle.

A copy of the report prepared by the representative of South Carolina

Department of Health and Environmental Control is enclosed as

Attachment 1. The report indicates that the shipment contained liquids in

excess of the allowable limits specified by Condition 32.B of the

South Carolina Radioactive Material License No. 097.

10 CfR Part 30.41(c) prchibits transfer of byproduct material unless it is

in a form authorized by the recipient's NRC or Agreement State License.

Condition 32.B of South Carolina Radioactive Material License No. 097,

Amendment 41, an Agreement State License issued to Chem-Nuclear Systems,

Inc., prohibits the receipt of solidified waste with " detectable free

standing liquid" which is defined as liquid in excess of 0.5 percent by

waste volume of non-corrosive liquids per container.

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According to the state representative, approximately 55 gallons of liquid

was found within the liner. Apparently, the liquid observed was released

from the solidification media used to solidify the waste. The 55 gallons

of free standing liquid represents approximately 3.7 percent by waste

volume; therefore, the transfer of byproduct material on May 19, 1986, to

Chem-Nuclear Systems, Inc., containing free standing liquid in excess of

Chem-Nuclear license limits is an apparent violation of 10 CFR

, Part 30.41(c) -(458/8622-01) .

7. Audits

The NRC inspector reviewed audits performed by the licensee of the

radwaste management. system to determine compliance with TS,

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Sect,1on 6.5.3.8s

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, The NRC inspector reviewed audits 86-02-I-PCON, " Process Control Program"

conducte'd during the period February 11-18, 1986, and 86-06-I-RWMP

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" Radioactive Waste Management Program," conducted June 17-27, 1986. The

, NRC inspector attended the exit interview held on June 30, 1986, for

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, audit 86-06-I-RWMP.

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The NRC inspector reviewed the audit checklist for both audits. The NRC

inspector noted that all items identified in audit 86-02-I-PCON had been

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satisfactorily resolved.

No violations or deviations were identified.

8. Transportation Activities

The NRC inspector reviewed the licensee's transportation program to

determine compliance with 10 CFR Parts 20 and 71, and DOT Regulations

40 CFR Parts 170-189.

a. Quality Assurance Program

The NRC inspector determined that the licensee had submitted a QA

program for approval to the NRC to comply with 10 CFR Part 71,

Subpart H. The licensee had received NRC Form 311, Quality Assurance

Program Approval, approval number 0566, Revision 0, dated January 13,

1986, with an expiration date of January 31, 1991.

b. Procedure and Selection of Packaging

The NRC inspector reviewed the licensee's program for procurement and

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seicetion of packaging for compliance with the requirements of 10 CFR

Parts 71.12 and 71.43 and 49 CFR Part 173.

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

certified packaging. The licensee had available appropriate

documentation on design, use, maintenance, testing, and NRC/ DOT

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certification. The licensee had applied for and received approval to

be placed on the users list for these packages.

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The NRC inspector noted the licensee had not made any shipments which

required DOT and NRC certified packaging.

c. Preparation of Packages for Shipment

The NRC inspector reviewed the licensee's program for preparation of'

packages for shipment to determine compliance with the requirements

of 10 CFR Parts 20.311, 71.12,.and 40 CFR Parts 172 and 173.

The NRC inspector noted that the licens'ee, in accordance with written

. procedures, assures that prior to each use the package: is proper

l for the contents to be shipped; is in unimpaired physical condition;

i is properly marked; complies with the radiation level ILmits at the

surface of the package; and removable non-fixed contamination is

below the regulatory limits.

d. Delivery of Completed Packages to Carrier

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The NRC inspector reviewed the licensee's program for delivery of

completed packages to a carrier for transport to determine compliance

with 10 CFR Parts 20.311, 71.55 and 49 CFR Parts 170 to 178.

4 The NRC inspector noted the licensee uses a shipment checklist to

j verify that regulatory requirements are being met.

! e. ' Receipt of Packages

The NRC inspector reviewed the licensee's program for receipt of

packages containing radioactive material to deternine compliance with

j , 10 CFR.Part 20.205.

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- The licensee's activities for receipt of radioactive material are

governed by procedure RSP-0205, " Receipt of Radioactive Material"

Revision 2, June 15, 1985. The NRC inspector reviewed this procedure

for consistency with regulatory requirements and to determine whether

it covired all aspects of the work being performed.

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f. Records, Reports and Notifications

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The NRC inspector reviewed the records for 9 of the 10 radioactive

material shipments"made during the calendar year 1985 and 23 of the

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37. radioactive material shipments made during the period January

through June 30, 1986, for compliance with the requirements of 10 CFR

Parts 20.311'and 61.80. The licensee maintains records of all

, radioactive material shipments as required. The records were

l complete with all shipping documentation, including the receipt and

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shipping radiation survey data.

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The NRC inspector reviewed the licensee's procedures for the radioactive

material handling and shipping program listed in Attachment 2.

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RNo violations or' deviations were identified.

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9. Solid Waste Management

The NRC inspector reviewed the licensee's solid radioactive waste

l- management program for compliance with TS 6.9.1.8, 6.10.2, 6.13 and 6.15'

j and commitments contained in Section 11.4 of the FSAR.

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The NRC inspector reviewed as installed and operational solid radwaste

system to determine agreement with the FSAR, Section 11.4.2.1, " General

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! - Description" Amendment 20, June 1985 and as depicted in Figure 11.4-1,

" System 604 Radwaste-Solid," Amendment 21, July 1985.

The NRC inspector noted that waste sludge tank and associated equipment

described in FSAR Section 11.4.2.2 had been completed, with the exception

l' of a sample valve, but was not operational. The licensee had installed a

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temporary bypass and spent resins were transferred to the Chem-Nuclear

i Systems, Inc. (CNSI) portable solidification system which is different

I than the system depicted in Figure 11.4.1. Section 11.4.2.3.1 of the FSAR

, states "GSU identifies the curie content and radionuclide identification

for waste to be solidified prior to delivery to CNSI." However, the NRC

1 inspector noted that the method used by the licensee is to transfer the

i vaste to CNSI and then take a sample from the waste and cement six for

curie content and radionuclide identification.

Section 11.4.2.3.3 of the FSAR identifies a waste compactor and discusses

! the operation of the compactor. However, the NRC inspector noted that the

licensee has not installed this waste compactor.

The NRC inspector discussed with licensee representatives the status of

the solid radwaste system and the scheduled completion of the system

, described in the FSAR. The NRC inspector stated that the failure to have

a solid radwaste system operational as described and depicted in the FSAR,

i Section 11.4 was considered an apparent deviation from this commitment

(458/8622-02).

l The NRC inspector discussed with licensee representatives the radioactive

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vaste segregation program. The licensee had implemented a waste

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segregation program after initial fuel loading and had segregated a small

amount of ~ waste, but had not released any material from the facility. The

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licensee was presently accumulating all material from the radiologically

controlled area and placing this material in steel containers or ateel

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uncompacted waste at the time of this inspection stored in various plant

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locations.

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J The NRC inspector expressed concern and discussed with licensee management

i the' excessive amount of dry uncompacted, unsegregated waste that was being

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accumulated at a rate of 15 to 30 cubic feet per day. The licensee stated !

that they had designated space to store approximately 3000 cubic feet of

s waste. 'During the exit interview on July 3, 1986, the licensee committed

'to implement.a waste segregation program prior to the October 1986 '

maintenance outage or dispose of the excess waste.

10. Exit Interview

The NRC inspec'or t met with the licensee representatives denoted in l

paragraph 1 at the conclusion of the inspection on July 3, 1986. The NRC

inspector summarized the inspection scope and findings.

The licensee committed to the NRC inspector to implement a waste

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segregation program prior to the October 1986 maintenance outage or

l dispose of excess waste.

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ATTACIDIENT 1

awwan wwwt.Ana ur.rAKint.Nr OFur.AMs AND F.HV AKUnnr. MAL wnanOL

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Bureau of Radiological Realth

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' Division of Radioactive Material Licensing and Compliance

n=diametive Shipment Inspecties Esport

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Emport No. 86-05-47

/semeral Inforesties:

/ 1. Shipper Culf States Utilities-River Bend Station Address St. Francisville. LA

2. Carrier Tri-State Motor Tractor f 2313 Trailer #345315 Type Platbed

/ 3. Type PackageigEIk 2 liners EIER Containing solidified resin in cement

B. Skipping Documsstation:

1. ASI 43264 Volume Allocation f 0586-126-A

2. Permit # 0232-17-86-X

Shipping Esse & Class: Radioactive u=*arialT LSA. mas

3. Total Burial Vol.: 412 M Id.f W 2912 (172.202(a))

4.

ftJ(172.202(c) Total curies: 0.06962 (172.203(d))

5.

Radionnelides:Cr-51. Ih-54. Co-58460. Pw-59. En-65. Er-95. Es & La 140 (172.203(d))

6. Describe chem./phy. media: solid metal oxides on resin solidified in cement (172.203(d))

Chelating Agente(%)t... ek.- nghippers Certification: State N

7. Exclusive Use %. DOT N (172.204)

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Instructions N (173.425(b)) Total T.I. EA (177.842(a))

8. Check for: Radiation Survey 'N T .441)

9. Compare: Radionuclides w/ resin analysis N Contamination Levels N (173.443)

Rad / Contamination Levels w/CESI/BRH N

i c. shipment Imopection Check List:

N- Shipment Braced / Blocked (173.425(b)(6)

' N Lids (Drum cask) secure (173.425)(b)

N Visible Leakage (173.425(B)(1) N Visible Damage (173.425)

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. Package Labelina: U-I, Y-II. III(172.403) EA Cask Defects /Misstag Parts ,

N Waste (b) & (c) or (Radioactive LSA) (173.425) T adiation

R Servey: Cab / sleeper.

Class. Marked B-C StableUnstabib

N Cross Weight Markad @(172.310) trailer / truck (173.441)

'N Contami=mtion Levels (173.443)

ILSA Exclusive Use Exempt]

N 4QType A Type B Package Marked (172.310)

e Vehicle Placards (173.425(c) (172.507)

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'a Trailer / Tractor Defects N4 Tiedoens Secare/ Adequate

I Offloading Discrepancies

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NA Packages banded / reinforced, ps11etized

D. Radiaties/ Coat-i-ties Serveys (transport vehicle or package)

(mR/hr) Surface: 4.0 2 meters:

Surface: Cab / sleeper

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Surface:

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2 meters: -

2 meterar

Surface: 4.0 2 meters: 0.5

Eighest contamination detected: Arrival 8 alpha dym/100 cad Belease dyn/100c 2

16 bete samme dym/100cm2 dgia/100cm2

E. Enemits of Inspecties: Summary of violations and discroyancies A Department inspectiam of

t his shionent revealed liould in excess of allowable limits ikSS Drsstemme). C-=.

M ==11 ann of if anid was drained from this liner wittr en}F P.35 maf3ses mI3esemble. TM

in ennerary to the reeuf r- nen~of 32.B of S.C. Radioactive Material License 097.; -

A=,nA-.ne ==A

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ennaritures a vioistian of Section 1.2. ta_.- ^ Be_e_=tation 61-83.

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Date: May 23, 1986 Inspector's Signet e s/ Richard S. Sappington

11 REC 810 (Rev.10 /84)

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ATTACHMENT 2

Procedures reviewed during NRC Inspection 50-458/86-22

ADM-0022 " Conduct of Operations," Revision 7, May 29, 1986 f

ADM-0038 " Radioactive Waste Managemsnt Program," Revision 3, May 29, 1986

ADM-0043 "Radwaste Management Plan," Revision 1, January 13, 1986

RWS-0203 " Personnel Qualification for Radwaste Section," Revision 2

July 24, 1985

RWS-0204 " Process Control Program," Revision 1, May 1, 1986

RWS-0305 "Use of the Dry Active Waste Storage Facility (DAWSF),"

Revision 2, May 6, 1986

RWS-0307 " Radioactive Waste Segregation," Revision 1, May 3, 1985

RWS-0308 " Evaluation and Determination of Shipping Container Activity,"

Revision 1, May 30, 1985

RWS-0313 " Receipt Inspection, Storage, and Inventory of Radioactive

Material Shipping Packages," Revision 2, June 17, 1986

PWS-0324 " Shipping Special Form Radioactive Material," Revision 2,

May 6, 1986

RWS-0325 " Shipping _,A 2 Quantities of Radioactive Material," Revision 2,

May 13, 1986

RWS-0326 " Shipping _A2 Quantities of Radioactive Material," Revision 2,

May 17, 1986

RWS-0329 " Shipping Empty Radioactive Containers," Revision 2, June 4,

1986

RWS-0330 " Shipping Limited Quantities of Radioactive Material,"

Revision 2 May 6, 1986

SD-OP-003-518 " Process Control Program for CNSI Cement Solidification Units

River Bend," Revision A. June 30, 1986

COP-0048 " Sampling of Spent Resin," Revision 1, March 25, 1985

ML20206N378

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