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Insp Rept 50-298/86-19 on 860609-13.Violations Noted: Failure to Survey & Identify Radioactive Shipment & Unauthorized Transfer of Licensed Matl
	ML20210B113
Person / Time
Site:	Cooper
Issue date:	07/31/1986
From:	Baer R, Murray B; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20209J436	List: ML20209J432; ML20209J438; ML20210B113;
References
	50-298-86-19, GL-81-38, NUDOCS 8609170453
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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-298/86-19 License: DPR-46

Docket: 50-298

Licensee: Nebraska Public Power District

F4cility Name: Cooper Nuclear Station (CNS)

Inspection At: Brownville, Nebraska

Inspection Conducted: June 9-13, 1986

Inspector: ~

R' E. Baer, Radiation Specialist, Facilities Date

Radiological Protection Section

Approved: b

B.Murray, Chief,FacilfiesRadiological Date

Protection Section

Inspection Summary

Inspection Conducted June 9-13, 1986 (Report 50-298/86-19)

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

radioactive waste and transportation programs, including: organization and

management controls, training and qualifications, changes to facilities

procedures, audits, quality assurance program, and records and reports.

Results: Within the areas inspected, three violations were identified:

(1) failure to survey, (2) failure to identify a radioactive shipment, and

(3) unauthorized transfer of licensed material (see paragraph 12).

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DETAILS

1. Persons Contacted

G. R. Horn, Division Manager, Nuclear Operations

R. L. Beilke, Chemistry and Health Physics Supervisor

G. D. Bray, Auxiliary Equipment Supervisor

T. J. Chard, Health Physicist

R. F. Drier, Training Material Specialist

R. Faust, Lead Electrical and Instrument and Control

Engineer-

C. Goings, Regulatory Compliance Specialist

D. Greenwalt, Radchem Engineering Technician ,

M. D. Hamm, Security Supervisor.

J. H. Kutler, Health Physics Specialist

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R. J. Mcdonald, Assistant Chemistry and Health Physics

Supervisor

J. A. Mehser, Radwaste Operator

E. M. Mace, Acting Technical Manager

J. V. Sayer, Acting, Technical Staff Manager

V. L. Wolstenholm, Quality Assurance Manager

Other Personnel

D. L. DuBois, Senior Resident Inspector, USNRC

E. A. Plettner, Resident Inspector, USNRC

Denotes those present during the exit interview on June 13, 1986.

The NRC inspector also interviewed several other-licensee employees,

including health physics, chemistry, maintenance, operations, and

administrative personnel.

2. Licensee Action on Previous Inspection Findings

(Closed) Open Item (298/8204-04): Calibration of Off-Gas and Stack

Effluent Monitoring (GE) - This item involved the lack of a full scale

calibration. The licensee had revised chemistry procedures 8.6.2, to

include a full scale calibration of these monitors. This item is

considered closed.

(Closed) Open item (298/8421-14): Stability Requirements of

10 CFR 61.56(b) - This item involved the lack of a documented program to

verify that solidified radwaste met the stability' requirement of

10 CFR 61.56(b). The licensee had revised radwaste procedure 2.5.4.1.

" Solid Wet Waste Packaging, Storage, and Transfer System" to include

testing and documentation of test results. This item is considered

closed.

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(Closed) Open item (298/8514-03): Frisker Response Testing - This item

involved the' lack of a formal program to verify that frisker monitors

were operational. The licensee revised Health Physics Procedure 9.3.4.3,

" Friskers" to include a periodic functional check to verify the instrument

operability. This item is considered closed.

(Closed) Open item (298/8526-02): Maintenance and Test Procedure

Compliance - This item involved the lack of health physics notification

prior to the performance of certain work evolutions. The licensee revised

procedure 7.5.2.6 to require health physics notification and added

Attachment "A" where the notification is documented by a sign-off step in-

the-procedure. This item is consiaered closed.

(Closed) Violation (298/8526-03): Radiation Protection Procedure

Compliance - This item involved the lack of a special work permit prior to

the performance of certain' work evolutions. The licensee revised

Procedure 7.5.2.6, "Tip Drive Torque Measurements and Core Top

Programming," Revision 8, dated March 21, 1986, to_ require that a special

work permit is issued for the tip tent room. This item is considered

closed.

3. Inspector Observations

The following are observations the NRC inspector discussed with the

licensee during the exit interview on June 13, 1986. These observations

are neither violations nor unresolved items. These items were recommended

for licensee consideration for program improvement, but they have no

special regulatory requirement. The licensee stated these items would be

reviewed:

a. Chemistry Procedure 8.6.2 - Inconsistencies exist in terminology

for source identification and sources used for calibrations. See

Paragraph 4-for additional details,

b. 00T-17H Steel Drums - The licensee does not purchase DOT-17H steel

drums from a supplier on their qualified vendor list. See

Paragraph 6 for additional details.

, c. Temporary Rubber Hose - The licensee uses temporary rubber hose for

transferring spent resins. See Paragraph 11 for additional details.

4. Organization and Management Controls

The NRC inspector reviewed the licensee's staff functional assignments

relating to solid radioactive waste and transportation programs to

determine compliance with Inspection and Enforcement (IE) Bulletin 79-19

, and Technical Specifications (TS) Section 6.1; and commitments in

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Chapter 13 of the Updated Safety Analysis Report (USAR).

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The NRC inspector determined that the licensee had not made any changes to

the organization and management controls since the previous inspection as

described in NRC Inspection Report 50-298/85-25.

The NRC inspector reviewed the procedures for the conduct of radioactive

material packaging, handling, transportation, and receipt operation listed

in Attachment 1. The NRC inspector noted that Chemistry Procedure 8.6.2,

"Kaman Vent Monitor and ERP-GE Calibrations," Revision 12, April 23, 1986,

in Section VI, " Material and Equipment," referenced Kaman and CNS numbered

planchet sources and in Section VII referred to disc sources by number,

but did not specify in all cases if these were the Kaman or CNS sources.

The NRC inspector discussed with licensee representatives this

observation. The licensee stated that the planchet and disc sources were

the same sources and all the sources used were not included in the

material and equipment section. The licensee stated that this procedure

would be revised.

No violations or deviations were identified.

5. Training and Qualifications

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

involved in the. transportation of radioactive material and solid

radioactive waste activities to determine compliance with the requirements

of IE Bulletin 79-19 and TS 6.1.4; commitments in Chapter 13 of the USAR;

and the recommendations of ANSI 18.1-1971.

The NRC inspector discussed the radioactive waste / transportation training

program with the chemistry and health physics supervisor, health

physicist, radiation specialist, radwaste operators, and several health

physics technicians. These discussions indicated that the personnel

involved in the processing and transporting of radioactive waste materials

possessed a working knowledge of the licensee's specific procedural

requirements and applicable NRC, Department of Transportation (DOT), and

burial site requirements.

The NRC inspector reviewed the training records of personnel in

operations, maintenance, quality assurance, and health physics who are

assigned to radioactive waste processing and transportation activities.

No violations or deviations were identified.

6. Audit Program

The NRC inspector reviewed the licensee's latest audit performed in

accordance with Procedure QAP-1200, " Quality Assurance Plan Radioactive

Waste Treatment and Disposal," Revision 7, March 6, 1985, during the

period April 8-25, 1985. The NRC inspector also reviewed selected quality

assurance surveillances performed on all waste shipments during the period

January 1985 ~through May 1986. The NRC inspector noted that the licensee

has routine QA check points that must be signed off for each radioactive

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waste shipment. The NRC inspector determined that QA personnel performing

surveillance activities had attended a course on transportation regulatory

requirements.

The NRC inspector discussed with licensee representatives the use of

55 gallon drums manufactured as DOT 17H containers. The licensee does not

purchase these containers'from a vendor on their qualified vendor list,

which means the QA Program that the drum manufacturer implemented has not

been verified. The NRC inspector cautioned the licensee that the

certificate of compliance for certain NRC/ DOT approved outer containers

may require the inner container also to be DOT approved. The NRC' inspector

determined the present NRC/ DOT containers being used by the licensee did

not includethis requirement.

No violations or deviations were identified.

7 .- Low-Level Radioactive Waste Storage Facility

The NRC inspector reviewed the status of the low-level radioactive waste

(LLRW) storage facility for compliance with 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 NRC inspector determined that the-licensee had not completed an onsite

LLRW facility. The licensee had designated a small area of the

Multi-Purpose Building which had been built to support the recirculation

pipe replacement program for short term miscellaneous LLRW storage.

No violations or deviations were identified.

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

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

determine comi tiance with the requirements of 10 CFR Parts 20.311, 61.55,

and 61.56.

The NRC inspector reviewed the licensee's LLRW program for generation of-

waste classification, waste form and characterization, labeling, tracking

of waste shipments, and maintaining a current copy of the disposal site

license. The licensee was currently implementing a LLRW program as

described in NRC Inspection Report 50-298/85-25.

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The licensee was in the process of revicing procedures concerning

correlation factors and the use of the portable spent resin dewatering

system.

No violations or deviations were identified.

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9. Spent Fuel Shipments

The NRC inspector reviewed the licensee's Procedure 9.5.3.7, " Cask IF-300

Shipment," Revision 3, December 26, 1985 and Nuclear Performance

Procedure 10.27, " CASK IF-300 Handling and Shipping," Revision 5,

April 30, 1986. The licensee had performed eight spent fuel shipments

during the period November 1, 1985, through June 13, 1986.

No violations or deviations were identified.

10. Transportation Activities

The NRC inspector reviewed the licensee's transportation program to

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

49 CFR Parts 170-189.

a. Procurement and Selection of Packaging

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

selection of packaging for compliance with the requirements of 10 CFR

Parts 71.12 and 71.54 and 49 CFR Part 173.

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

certified packaging. The licensee had available the appropriate

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

certification. The licensee was on the users' list for all NRC/ DOT

packaging being used.

b. 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 0485, Revision 1, expiration date

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November 30, 1987.

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 20.311 and 71.12 and 49 CFR Parts 171, 172, and 173. (See

paragraph 12 for apparent violations of shipping requirements.)

d. Delivery of Completed Packages to Carrier

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 and 71.55 and 49 CFR Parts 170 to 178.

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The NRC . inspector observed the licensee preparing, loading, labeling,

placarding, surveying, and completing shipping documentation for two

casks, each loaded-with fourteen 55 gallon drums of solidified radioactive

waste.

e. Receipt of Packages

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

packages containing radioactive material to determine compliance with '

10 CFR Part 20.205.

The licensee's activities for receipt of radioactive materials are

covered by procedure 9.5.1, "Receival of Radioactive Materials,"

Revision 3. The NRC inspector reviewed this procedure for

consistency with regulatory requirements and to determine whether it

covered all aspects of the work being prepared.

f. Records, Reports, and Notifications

The NRC inspector reviewed selected records of 34 radioactive

material shipments for the 78 shipments made by the licensee during

calendar year 1985 and 22 of the 57 shipments made during the period

January 1 through May 30, 1985, for compliance with the requirements

of 10 CFR Parts 20.311 and 61.80. The licensee maintained records of

all radioactive material shipments as required. The records were

. complete with all shipping documentation, including the receipt and

shipping survey data.

11. Solid Waste Management

The NRC inspector reviewed the licensee's solid radioactive waste

management program for compliance with commitments contained in Chapter 9

of the USAR.

The'NRC inspector reviewed special test Procedure 85-14, "CNS/ Nuclear *

Packaging Onsite Radwaste Procedure," which the licensee had developed for

the temporary spent resin dewatering system and other associated

evaluations the licensee had performed prior to the in'stallation of the

equipment. The licensee had performed a 10 CFR Part 50.59 safety review

and determined that this equipment would not be an unreviewed safety

question and no technical specification changes would be necessary.

The NRC inspector discussed with licensee representatives the temporary

hose that was connected to the permanent radwaste transfer piping system

in the "A" centrifuge room on the third floor of the radwaste building

connecting the liner and dewatering equipment located in the truck bay

area of the augmented radwaste building. The licensee stated that they

were in the process of purchasing a portable solidification type of system

for permanent installation and that hard piping would be installed. The

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NRC inspector referenced the industry standard ANSI /ANS-55.1 1979,

"American National Standard for Solid Radioactive Waste Processing System

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for Light' Water Cooled Reactor Plants," as the standard the licensee should

consider for minimum radius bends, valves, piping, and welding, in

addition to the ALARA review of the permanent installation. The. licensee

stated they would take this into consideration during the dqsign phase.

No violations or deviations were identified.

12. Inspector Followup on Licensee Event Reports (LER)

The NRC inspector reviewed the circumstances and licensee evaluations

regarding the incident of April 17, 1985, where the licensee

returned to a contractor a leased sandblaster containing approximately

170 pounds of aluminum oxide contaminated with about 16 microcuries of

cobalt-60. This inciaent was documented in LER 86-010-00.

The licensee had returned to a contractor on April 17, 1985, a sandblaster

4 which had been crated ard supposedly surveyed on April 10, 1985. An

. " unconditional release" tag on the original crate identified the contents

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as a " Hopper" and indicated smearable radiation levels of less than 100

disintegrations per minute (dpm) per 100 square centimeters (cm2 )

beta gamma and less than 1 millrem per hour fixed beta gamma.

The sandblaster was received by the contractor and remained crated in

their warehouse until March 16, 1986, at which time it was removed from

the original shipping crate, the 170 pounds of aluminum oxide grit removed,

and the sandblaster sent to another nuclear utility, where it was found to

be contaminated during a receipt inspection. Radiation levels observed

were 200 to 600 counts per minute on the sandblaster. Further surveys

indicated smearable contamination levels of 3000 to 6000-dpm/100 cm2 on

the wheels to the sandblaster, discharge line end, and bed of the transport

truck directly below the sandblaster. No other contamination was detected

on the truck or other associated equipment in the shipment. The truck bed

was decontaminated prior to releasing the vehicle.

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10 CFR 71.5(a) requires, in part, that each licensee who delivers licensed

material to a carrier for transport shall comply with the applicable

requirements of DOT in 49 CFR Parts 170 through 189. 49 CFR 173.475(1)

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requires, in part, that before each shipment of any radioactive package,

the shipper shall ensure by examination or appropriate test that external

radiation and contamination levels are within the allowable limits

specified in this subchapter. The NRC inspector determined on June 12, ,

1986, that the licensee failed on April 10, 1985, to perform adequate

surveys of a hopper containing contaminated grit prior to shipping the

hopper to an offsite vendor facility. The failure to perform adequate

surveys is an apparent violation of 49 CFR 173.475(i). (298/8619-01)

10 CFR 71.5(a) requires, in part, that each licensee who delivers licensed

material to a carrier for transport shall comply with the applicable

requirements of 00T in 49 CFR Parts 170 through 189. 49 CFR 171.2(a)

requires, in part, that "No person may offer . . . hazardous material for

transport in commerce unless that material is properly classed, described,

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packaged, marked, labeled, and in condition for shipment as required or

authorized by this subchapter . ... "

49 CFR 173.421(d) requires, in

part, for the shipment of limited quantities of radioactive materials,

that "the outside of the packaging itself bears the marking

'RADI0 ACTIVE'." The NRC inspector determined on June 12, 1986, that on

April 17, 1985, a shipment of a sandblaster involving about 170 pounds of

aluminum oxide grit contaminated with about 16 microcuries of cobalt-60

was shipped to an offsite vendor facility. .The inspector also determined

that the packaging was not identified as a radioactive shipment. .The

failure to properly identify the radioactive shipment is an apparent

violation of 10 CFR 71.5(a), 49 CFR 171.2(a), and 49 CFR 173.421(d).

(298/8619-02)

The contractor to which the sandblaster was returned was not authorized to

receive, possess, use, store or transfer any byproduct material. 10 CFR

Part 30.41(b)(5) prohibits the transfer of byproduct material except to

persons authorized-to receive such byproduct material under terms.of a

specific license or a general license or their equivalent issued by the

Atomic Energy Commission, the Commission, or an Agreement State. The NRC

inspector stated that the transfer of approximately 17_0 pounds'of aluminum

oxide grit containing 16 microcuries of cobalt-60, a byproduct material,

to a vendor in an Agreement State who did not possess a specific license or

a general license or their equivalent issued by the Atomic Energy

Commission, the Commission, or the Agreement State was considered an

apparent violation of 10 CFR Part 30.41(b)(5). (298/8619-03)

The NRC inspector noted that the licensee had recovered the aluminum oxide

grit and the original crate from the contractor's facility and verified

that the warehouse and equipment in the warehouse were not contaminated.

The nuclear utility where the sandblaster had been sent was in control of

this piece of equipment.

13. Exit Interview

The 'NRC inspector met with the NRC resident inspector and licensee-

representatives denoted in Paragraph 1 at the conclusion of the inspection

on June 13, 1986. The NRC inspector summarize.d the scope and findings of

this inspection, including the observations identified in paragraph 3.

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ATTACHMENT I

PROCEDURES REVIEWED DURING NRC INSPECTION 50-298/86-19

~2.5.3.1 Radwaste Support System Waste Collector Filter Revision 8,

May 22, 1986

2.5.3.2 Radwaste Support System Floor Drain Collector Filter, Revision 8,

May 29, 1986

2.5.3.4 RWCU Filer Demineralizer, Revision 12, October 12, 1986

2.5.3.5 Waste Demineralizer, Revision 16, September 12, 1985

2.5.4.1 Solid Wet Waste Packaging, Storage, and Transfer System,

Revision 13, February 13, 1986

9.5.3.3 Condensate Cleanup Waste Resins and Certain Other Wastes

Classification and Listing, Revision 2, October 17, 1985

9.5.3.4 RWCU Waste Resins Classification and Listings, Revision l' ,

October 17, 1985

9.5.3.5 Dry Radioactive Waste Classification and Listing, Revision 3,

October 17, 1985

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9.5.3.7 Cask IF-300 Shipment, Revision 3, December 26, 1985

10.27 CASK IF-300 Handling and Shipping, Revision 5, April 30, 1986

SP-85-14 CNS/ Nuclear Packaging On-Site Radwaste Processing,' Revision 0,

September 20, 1985

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