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{{Adams | |||
| number = ML20137W986 | |||
| issue date = 11/29/1985 | |||
| title = Insp Rept 50-382/85-26 on 851007-11.Violations & Deviation Noted:Failure to Conduct Specified Training Courses,Failure to Provide Proper Storage for Shipping Containers & Use of Addl Low Level Radwaste Storage Areas | |||
| author name = Chaney H, Murray B, Spitzberg D | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000382 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-382-85-26, IEB-79-19, NUDOCS 8512100391 | |||
| package number = ML20137W961 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 17 | |||
}} | |||
See also: [[see also::IR 05000382/1985026]] | |||
=Text= | |||
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. | |||
APPENDIX C | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
, | |||
REGION IV | |||
-[ NRC Inspection Report: 50-382/85-26 License: NPF-38 | |||
. Docket: -50-382 | |||
Licensee: Louisiana Power & Light Company (LP&L) | |||
ATTN: R. S. Leddick, Senior Vice President | |||
Nuclear Operations | |||
142 Delaronde Street | |||
4 | |||
New Orleans, Louisiana 70174 | |||
Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3) | |||
Inspection At: Taft, St. Charles Parish, Louisiana (Wat-3 site) and | |||
Generai Office in New Orleans, LA | |||
. Inspection Conducted: October 7-11, 1985 | |||
' | |||
Inspectors; n[- , / #-27-86 | |||
H.Chan'e9~,IT(did.igfSpecialist, Facilities Date | |||
Radiological Prot %ction Section | |||
, | |||
du Ma,, //-Z7-d5 | |||
D. B. Spitzberif, ifadfation Specialist, - Date | |||
Facilities Radiolobical Protection | |||
-Section | |||
~ | |||
,.i | |||
A~ | |||
p proved: [//c 1/11tztd ///BW65 | |||
B. Murray, Chief,' Facilit/tes Radiological | |||
~ | |||
i Dage / | |||
' | |||
Protection Section / | |||
Inspection Summary | |||
Inspection Conducted October 7-11, 1985 (Report 50-382/85-26) | |||
., | |||
, Areas Inspected: Routine, unannounced inspection of the licensee's radioactive | |||
material (RAM) shipment program, solid radioactive waste (radwaste) management | |||
i | |||
8512100391Bj0 | |||
ADOCK O | |||
82 | |||
PDR PDR | |||
G | |||
: _ _ _ _ _ __ _- _. _- _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ ~ | |||
- | |||
. | |||
2 | |||
program, and activities involving onsite storage of low-level ' radioactive | |||
waste (LLRW). The inspection involved 75 inspector-hours onsite and | |||
7 inspector-hours offsite by two NRC inspectors. | |||
Results: Within the areas inspected, two violations, (see paragraphs 4 and 5), | |||
and one deviation (see paragraph 7) were identified. | |||
s | |||
.. o | |||
3 | |||
DETAILS | |||
1. Persons Contacted | |||
LP&L- | |||
-R.-Barkhurst, Plant Manager | |||
*S. Alleman, Assistant Plant Manager | |||
. | |||
*R. Kenning, Radiation Protection Superintendent | |||
*L. Simon, Radwaste Engineer | |||
*K. Brewster, Licensing Engineer | |||
*R. Cornell, Independent Safety Engineering Group, Engineer | |||
*D._.'Stevens, Radwaste Supervisor | |||
*M. Moe, Radwaste Supervisor | |||
*D.~ Landeche, Health Physics (HP) Supervisor | |||
*R. Pittman, Operation Quality Assurance (QA) Supervisor | |||
*J. Woods, Quality Control (QC) Manager | |||
'*D. Rieder, Radwaste Associate Engineer | |||
- | |||
. | |||
'J. Etheridge,' LP&L General Office (GO), Radiation Control Unit, | |||
Radwaste Engineer - | |||
E. Fields, Engineering Nuclear' Safety, Engineer | |||
J. Messina, QA-Representative | |||
'G. Wuller, Onsite Licensing Coordinator | |||
W. Perry, Chemistry and Radwaste Training Instructor | |||
~J. O'Hern, General Training Superintendent | |||
" Denotes those present at the exit interview on October 11, 1985. | |||
The NRC inspector also interviewed several other licensee and contractor | |||
personnel. | |||
2. Licensee Actions on Previously Identified Inspection Findings | |||
.(Closed).0 pen Item (382/8512-02): Pre-use Response Check for Radiation # | |||
-Measurement Instruments --This item was previously discussed in NRC | |||
Inspection Report 50-382/85-12 and_ involved the licensee's7 1ack of a | |||
suitable pre-use response check for the Eberline teletector high range | |||
probe. The licensee had implemented a revision to HP Directive 83-1 which | |||
provided for response checking the high range probe of the teletector | |||
prior to use. Several teletectors were inspected for documentation of the | |||
required response check. This item is-considered closed. | |||
3. Organization and Management Controls | |||
The NRC inspectors reviewed the licensee's onsite and offsite organiza- | |||
tions that were involved with RAM transportation, radwaste operations and | |||
> | |||
. | |||
4 | |||
management to determine compliance with the commitments contained in the | |||
Final Safety Analysis Report (FSAR), Sections 11,12, and 13; and the | |||
requirements of the facility operating license Technical Specifications | |||
(TS), Section 6; NRC Inspection & Enforcement (I&E) Bulletin 79-19, and | |||
the recommendations in NRC Branch Technical Position (BTP) concerning | |||
waste classification and characteristics. | |||
The NRC inspectors determined that th radwaste organization agreed with | |||
the organizational chart depicted in Figure 6.2-2 of the TS. The licensee | |||
had developed position descriptions for personnel functional assignments- | |||
and designated a specific individual as being responsible for LLRW and the | |||
transportation of RAM. | |||
The NRC inspectors reviewed procedures and a computerized program for LLRW | |||
classification, characterization, and shipping document preparation. The | |||
procedures reviewed are listed in the Attachment I to this report. | |||
The NRC inspectors reviewed the licensee's Process Control Program (PCP), | |||
the vendor's solidification PCP, and operating procedures. The NRC | |||
inspectors discussed with the licensee the apparent lack of positive | |||
control over vendor procedures used for solidification operations. This | |||
item was also noted as a finding in a recent licensee QA audit | |||
(SA-W3-QA-85-12). The licensee stated that actions were being taken to | |||
place vendor procedures under their change and revision control. The | |||
licensee was noted to have developed a special scope QA document (Nuclear | |||
Operations Management Manual-NOMM, Section VI, Chapter 5) for general | |||
radwaste management and the establishing of specific QA/QC policies for | |||
compliance with 10 CFR Part 71, Subpart H requirements. | |||
The NRC' inspectors reviewed the licensee's program for appraisals and | |||
audits of transportation and radwaste activities. Recent audits and | |||
appraisals (SA-W3-QA-84-47, SA-W3-0A-85-12, and RCU Appraisal 85-2) of | |||
radwaste and transportation activities, including management and training | |||
aspects w~re reviewed. The NRC inspectors noted that the licensee's | |||
auditor checklists and audit notes were not of a sufficient depth to | |||
ensure that all of the NOMM's directives had been implemented in the | |||
radwaste program. The NRC inspectors also reviewed responses to audit | |||
findings and the program for ensuring audit findings were resolved in a | |||
timely manner. The NRC inspectors noted to the licensee at the exit | |||
meeting that, currently, there are no personnel in the operations- QA audit | |||
group with technical expertise in the field of radwaste and transportation- | |||
activities. .The licensee stated that they are considering recruiting | |||
personnel with HP,-radwaste/ transportation experience and that future | |||
audits of radwaste activities would evaluate implementation of the | |||
radwaste program. | |||
No violations or deviations were identified. | |||
- | |||
. | |||
5 | |||
4. Training and Qualification | |||
The NRC inspectors reviewed the licensee's training and qualification | |||
program for perscnnel assigned transportation and radwaste duties to | |||
determine compliance with commitments contained in the FSAR, Section 13; | |||
and the requirements of TS 6.3, 6.4; and I&E Bulletin 79-19, and the | |||
recommendations of industry standards ANSI /ANS 3.1-1978 and | |||
ANSI N18.1-1971. | |||
. | |||
The NRC inspectors reviewed course' descriptions, lesson plans, personnel | |||
training records, QA audits, and held discussions with training department | |||
personnel. The NRC inspectors were informed by training department | |||
personnel that the Institute of Nuclear Power Operation's (INPO) | |||
accreditation program for training of plant personnel did not specifically | |||
include radwaste activities involving transportation or the handling of | |||
LLRW (compaction and solidification), and that current performance based | |||
training development did not provide for task analysis in radwaste | |||
functional areas. The NRC inspectors noted to the licensee that the NRC | |||
would expect the licensee to maintain the training and retraining program | |||
for radwaste activities. | |||
The NRC inspectors reviewed the training qualifications of several rad- | |||
waste group personnel that performed compaction of LLRW to determine | |||
compliance with IE Bulletin 79-19 and licensee procedures. Radwaste | |||
Technical Procedure RW-02-200, " Packaging Radioactive Solid Waste (DAW) | |||
for Disposal," specifies that personnel performing compaction using the | |||
B-100 compactor (large box type compactor) must have completed training in | |||
the following areas: | |||
* General Employee Training, | |||
* Redwaste Training in accordance with UNT-03-018, "Radwaste Helper and | |||
Radwaste Technician Training Procedure," | |||
-* Instruction in the operation of the B-100 waste compactor, | |||
* The handling of radwaste in accordance with procedure RW-02-200, and | |||
* Qualification training for forklift truck operation, including | |||
demonstrating operating ability. | |||
The NRC inspectors determined on October 10, 1985, that a contracted | |||
employee had compacted DAW using the-B-100 compactor approximately 18 | |||
times,.during the period July 18 through September 5, 1985. Contrary to | |||
the above requirements, licensee training records showed that out of the | |||
five specific training courses referenced above, the contractor employee | |||
_ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
m | |||
. | |||
6 | |||
had only received the General Employee training. Failure to conduct the | |||
specified training is considered a violation of TS 6.8.1 (382/8526-02). | |||
.The NRC inspectors reviewed Nuclear Training Department radwaste course | |||
descriptions, lesson plans of completed courses, attendance rosters, and | |||
tests. The NRC inspectors noted that, with the exception of the employee | |||
noted above, all other employee's inspected (including contractor. | |||
. personnel) were qualified for their functional area assignments. | |||
No deviations were identified. | |||
5. Radioactive Material Transportation Program | |||
The NRC inspectors reviewed the licensee's transportation program for | |||
compliance with the requirements of 10 CFR Part 71, and DOT regulations | |||
49 CFR Parts 171 through 178, the NRC I&E Bulletin 79-19, commitments | |||
contained in Sections 11.4.4 and 12.5.1.3 (K) and (1) of the FSAR, the | |||
recommendations in I&E Notices 83-10, 84-14, and 84-50, NRC Regulatory | |||
Guides (RGs) 7.1 through 7.10, and the guidance contained in NUREG-0923 | |||
and the licensee's commitments. | |||
The NRC inspectors determined that since receiving their operating license | |||
in December 1984 the licensee had not shipped any radioactive material | |||
other than low specific activity (LSA) waste that did not exceed Type A | |||
quantities. Therefore, only strong, tight containers have been used by | |||
the licensee.for seven such shipments. | |||
a. Quality Assurance Program and Audits | |||
The NRC inspectors reviewed the licensee's QA program for compliance | |||
with the requirements of 10 CFR Part 71, Subpart H. QA attributes | |||
governing the procurement of packaging, use of packaging, and ship- | |||
ment of RAM is set forth in Attachment I to Chapter 5 of Section VI | |||
to the NOMM (see paragraph 3 above). This quality program satisfies | |||
the requirements of 10 CFR Part 71.101(b). The licensee has also | |||
notified the NRC concerning the requirements of 10 CFR Part 71.101(f). | |||
A review of licensee procedures for the shipment of RAM showed the | |||
extensive use of independent QC verifications and checklists for . | |||
container loading and closing. The licensee's audits to date had | |||
been conducted prior to the licensee shipping any RAM. However, the | |||
< | |||
licensee's radwaste contractor'had conducted an appraisal of RAM | |||
shipping during June of this year and reviewed the radwaste | |||
activities associated with one shipment and noted no deficiencies. | |||
j. | |||
, | |||
, | |||
- | |||
7 | |||
b. Procedures . | |||
The licensee's procedures for selection of packaging, preparation for | |||
shipment, marking / labeling / placarding, mcnitoring for radiation and | |||
contamination, and criteria for disposal site acceptance were | |||
reviewed and found to be satisfactory except for the form used in | |||
.RW-02-500, _.for determining the dose rate from a package for curie | |||
content estimation. The NRC inspectors noted that the instructions | |||
on the form were confusing and that values for average container dose | |||
rates were in error on a majority of the shipments reviewed. The | |||
. licensee's representatives stated that HP personnel filling out the- | |||
-forms were making the errors due to the complexity of the forms and | |||
insufficient training. The licensee representative further stated | |||
that the data from the forms were not used to estimate the curie | |||
content of containers previously shipped since the computerized RAM | |||
shipping program for waste containers, utilized shipment specific | |||
radicchemistry analysis results for determining each container's | |||
curie content. The licensee stated at the exit meeting that the | |||
subject form would the revised to make it simpler to use. | |||
c. Procurement and Selection of Packagings | |||
The licensee was found to have implemented detailed instructions on | |||
the. procurement and receipt inspection of shipping con- | |||
tainers /packagings. This included both DOT specification and NRC | |||
certified packages. | |||
The NRC inspectors noted during the period October 7 through 10 that | |||
the licensee had stored approximately eight steel liners, used for | |||
the solidification or dewatering of LLRW resins / wetted solids and as | |||
LSA shipping containers, in an area which was not protected from | |||
inclement weather. These containers / liners had been stored outside | |||
of the security fence opposite the Services Building on the west side | |||
of the plant. These storage conditions are contrary to the | |||
requirements in procedure RW-02-300, " Receipt, Storage and Loading of | |||
Shipping Containers," paragraph 6.1.1, which requires that all DOT | |||
specification, strong, tight, and certified shipping containers shall | |||
be stored to minimize exposure to inclement weather conditions. | |||
Failure to provide proper storage is considered a violation of | |||
TS 6.8.1 (382/8526-01). | |||
d. Determination of Package Activity and Radionuclides | |||
The NRC inspectors reviewed the licensee's methodologies for deter- | |||
mining the curie content of packages. The licensee's computerized | |||
radwaste management program (RADMAN) provides for establishing a | |||
, | |||
containers curie content by either direct input of quantitative | |||
radiochemistry analyses or by a default program using generic PWR | |||
s | |||
. | |||
8 | |||
waste stream radionuclide concentrations and a dose rate to curie | |||
estimation based on Rockwell International shielding methodologies. | |||
-The licensee currently uses the method of directly inserting quantita- | |||
tive radiochemistry analyses into the data base of each shipment. As | |||
noted in paragraph 5.b above, the licensee is reevaluating the | |||
current dose rate averaging method for packages. | |||
e. Preparation of Packages for Shipping | |||
The NRC inspectors reviewed the licensee's procedures for the receipt | |||
inspection, opening, loading and closure of shipping containers and | |||
casks. The NRC inspectors discussed with licensee representatives | |||
the QC inspections set forth in shipment preparation procedures and | |||
the expected degree of-QC involvement in each shipment. | |||
Plant proc.edure RW-2310, Revision 1, " Storage of Loaded Shipping | |||
Containers," paragraph 6.2, requires all loaded shipping containers | |||
to be stored in weather tight buildings or enclosures. The NRC | |||
inspectors determined on October 10, 1985, that the licensee had | |||
stored approximately 114 filled LSA strong, tight shipping containers | |||
(22 solidification liners and 92 steel, B-25 shipping containers) | |||
outside in an area exposed to ambient whether conditions. This is a | |||
second example.of failure to provide proper storage for materials | |||
important to quality and is an apparent violation of T.S. 6.8.1 and | |||
station procedures (382/8526-01-see paragraph 5.c above). | |||
The NRC inspectors noted that many of the containers (B-25 steel | |||
boxes) were filled with condensate polisher resins, which involved | |||
low-level radioactive contamination for which the licensee is | |||
petitioning the NRC to allow onsite burial per-10 CFR Part 20.302 | |||
criteria. The NRC inspectors also noted that the B-25 containers | |||
have been accumulating since the April 1985 incident involving a | |||
primary to secondary leak, Licensee Event Report No. 85-13, and that. | |||
there was no program / procedure for the periodic inspection of the | |||
containers' physical condition. | |||
f. Delivery of Packages to Carriers | |||
The NRC inspectors reviewed the licensee's shipping documents for the | |||
eight RAM shipments made by the licensee since the start of facility | |||
operations. The documents were reviewed for content and accuracy | |||
concerning DOT proper shipping name, hazard classification, hazard | |||
identification number, listing of radionuclide inventory, description | |||
of contents (physical and chemical), curie content, category of | |||
labels applied to the package, determination of DOT transport index | |||
val ~ue, placarding applied to the transport vehicle, and whether any | |||
chelating agents were present in LLRW. The licensee's shipping | |||
- . _ - - _ _ - _ - - - - - - _ _ - - | |||
' | |||
, | |||
. | |||
. | |||
9 | |||
documents indicate that past packages delivered to carriers satisfied | |||
the requirement of 49 CFR Parts 100 through 177, and those of 10 CFR | |||
Part 20.311. | |||
g. Receipt of Packages | |||
The NRC inspectors reviewed the licensee's procedures and records for | |||
receipt of radioactive material and determined that the requirements- | |||
of 10 CFR Part 20.205 and recommendations of RG 7.'s were being met. | |||
h '. ' Transportation Incidents. | |||
The NRC inspectors determined,'by discussions with licensee representa- | |||
tives, that none of LP&L's RAM shipments had been involved in accidents | |||
or incidents. Also, no violations have been noted on RAM received. | |||
i. Records, Reports, and Notifications | |||
The NRC inspectors reviewed the licensee's procedures and records for | |||
RAM shipments. The NRC inspectors noted to the licensee that there | |||
appeared to be insufficient independent review of the entire shipping | |||
document package prior to package shipment. The licensee stated that | |||
this aspect of the program would be looked into for possible improve- | |||
ment. The licensee's shipment notification program appears to | |||
satisfy the requirements of 10 CFR Part 71.89. | |||
No' deviations'were noted. | |||
6. Low-Level Radioactive Waste Management Program | |||
The NRC inspectors reviewed the licensee's program for the control, | |||
classification, characterization, and shipment of low-level radioactive | |||
waste to' determine compliance with the commitments contained in | |||
-Section 11.4 of the FSAR; and the requirements contained in 10 CFR | |||
Parts 20.301, 311, 61.55, and 61.56; and TS 6.5.1.6.n, 6.8.1.1, 6.13, | |||
and 6.15; and the recommendations of NRC BTP papers on LLRW classification | |||
and waste form, | |||
a. Procedures | |||
The NRC inspectors reviewed the licensee's process control program | |||
procedure, implementation of the RADMAN computerized LLRW management- | |||
system (including the internal programs for LLRW shipment tracking, | |||
waste manifest preparation, waste classification, and curie content | |||
estimation), QA and G0 audits of LLRW activities, plant waste stream | |||
sampling and analysis procedures, and implementation of the LDCL | |||
Special Scope QA program for radwaste activities. | |||
' | |||
. | |||
10 | |||
b. Sampling and Analysis | |||
The NRC inspectors reviewed the licensee's scaling factors program | |||
for the inventory of radionuclides. This generic model is based on | |||
several Combustion Engineering type pressurized water reactors. The | |||
NRC inspectors discussed with licensee representatives the licensee's | |||
future plans on periodic sampling of waste streams and the developing | |||
of plant specific scaling factors. The licensee's planned program | |||
includes semiannual sampling of waste streams with analyses by an | |||
offsite laboratory in conjunction with quarterly samples analyzed by | |||
the onsite radiochemistry group. | |||
c. Effluent Release and Controls | |||
The NRC inspectors reviewed the licensee's controls over the release | |||
of RAM to unrestricted areas. The licensee had implemented personnel | |||
training (general employee and radiation worker), and detailed | |||
procedures for the handling, control and surveying of potentially | |||
contaminated material. The licensee's controls, equipment, and | |||
procedures were reviewed, as well as actual processing of potenti- | |||
ally contaminated materials by HP personnel. The NRC inspectors | |||
discussed with licensee representatives the NRC's position on use of | |||
state-of-the-art radioactivity measurement equipment for evaluating | |||
the radiological status of materials being released from licensee | |||
control. The NRC inspectors emphasized to the licensee the restrict- | |||
ions placed on 10 CFR Part 50 licensees concerning release of | |||
radioactive material as discussed in NRC I&E Information Notice | |||
No. 83-05. | |||
The licensee informed the NRC inspectors that they were pursuing a | |||
petition to the NRC for establishing an onsite waste burial facility | |||
for the disposal of very low-level radioactively contaminated con- | |||
densate polisher resins per 10 CFR Part 20.302 and the guidance | |||
contained in the above noted I&E Information Notice. | |||
d. Operations and Maintenance of Facilities and Equipment | |||
lhe NRC inspectors determined that the licensee had elected not to | |||
use the installed plant solidification system, but was using a vendor | |||
provided and operated solidification system. The vendor's PCP and | |||
procedures have been accepted by the NRC as meeting the requirements | |||
of 10 CFR Part 61.56. Due to the licensee's nonradiological | |||
limitations on boron in discharged liquids from the plant, the | |||
licensee is utilizing a supplemental demineralizer system (vendor | |||
provided and operated) for treatment of waste liquids. The licensee | |||
had provided for the continuous monitoring of airborne radioactivity | |||
within the temporary solidification facility and specific work area | |||
grab sampling during solidification activities; also the licensee had | |||
provided monitoring instrumentation and HEPA filtered ventilation | |||
- - - _ _ _ . | |||
- | |||
* | |||
. | |||
11 | |||
system for the waste segregation and compaction facility. The | |||
licensee also stated that revisions to the FSAR, Section 11.4.8.1 | |||
were being planned to resolve the description inaccuracies concerning | |||
the ventilation system on the DAW waste compactor. The licensee's | |||
actions noted above resolve the NRC's. concerns about the temporary | |||
solidification facility and the waste compaction building which were | |||
discusseo in NRC Inspection Report 50-382/84-38. | |||
e. Reports | |||
The NRC inspectors reviewed the licensee's semiannual Radioactive | |||
Effluent Release Report, documented changes to the solid radwaste | |||
system, and PCP procedure changes submitted to the NRC per TS 6.9.1.8 | |||
for the period March 4 (initial criticality) through June 30, 1985. | |||
Since issuance of an operating license in December 1984 the | |||
licensee's LLRW inventory has been: | |||
LLRW in | |||
Shipments LLRW to be Long Term | |||
Types of LLRW To Burial Shipped Storage | |||
DAW 950 ft' 190 ft2 none | |||
Wetted Wastes 3094 ft' 1092 ft' 8155 ft'* | |||
* Denotes waste being held pending 10 CFR Part 20.302 determination. | |||
7. Onsite Low-Level Radioactive Waste Storage | |||
The' licensee's onsite low-level radioactive waste storage facilities were | |||
reviewed for agreement with the guidance provided in NRC Generic | |||
Letter 81-38, and the licensee's commitments contained in Sections 11.4.6 | |||
and 11.4.7 of the FSAR. | |||
The NRC inspectors determined that the licensee had developed. plans and | |||
selected a building site for an interim LLRW storage and DAW compaction | |||
facility of approximately 24,000 square feet. The scheduling for start'of | |||
construction is being held in abeyance pending the outcome of state burial | |||
site compact negotiations and federal legislation'on keeping existing | |||
burial sites open. The licensee's plans appear to incorporate all the | |||
design aspects discussed in the NRC Generic Letter, and NRC BTP-ETSB'11-3. | |||
The FSAR in Sections 11.4.6, 11.4.7, and 11.4.8 identifies LLRW storage | |||
areas in the following locations: | |||
a. Reactor Auxiliary Building Solidification Facility (11.4.6), | |||
_---_4 | |||
c | |||
, | |||
12 . | |||
b. An outside lay down area (concrete slab) on the east side of the dry | |||
cooling towers (11.4.7), and | |||
c. Interim Dry Compacted Waste Facility (11.4.8). | |||
The NRC inspectors determined on October 10, 1985, that the licensee had | |||
established approximately four additional LLRW storage areas other than | |||
those referenced in the FSAR. The licensee had established storage for | |||
a;. proximately 114 filled LLRW shipping containers in 4 additional areas of | |||
the plant as follows: | |||
* | |||
West side of the turbine building (approximately 71 containers), | |||
* Southwest corner of the switchyard fence (approximately 19 | |||
containers), | |||
* | |||
East side of the switchyard fence (approximately 2 containers), and | |||
. East side of the turbine building (approximately 22 containers). | |||
The use of additional LLRW storage areas is considered a Deviation of | |||
Commitments in the FSAR (382/8526-01). | |||
8. Exit Interview | |||
The NRC inspectors met with the licensee's representatives identified in | |||
paragraph 1 of this report at the conclusion of the inspection on | |||
October 11, 1985. The NRC inspectors summarized the scope and the results | |||
of the inspection. In response to the inspectors comments and concerns | |||
the licensee provided the following commitments: | |||
a. More positive control will be exercised over vendor procedures used | |||
in the LLRW processing program, | |||
b. The forms and methodologies for determining dose rate information | |||
used in RAM shipment curie estimation will be reevaluated. | |||
c. An independent review program will be implemented concerning the | |||
completed RAM shipment dccument packages. | |||
_ _ - _ | |||
.________ ___ _-_ ___ _ _ - - _ _ _ _ - - | |||
. | |||
ATTACHMENT 1 | |||
TO NRC INSPECTION REPORT | |||
50-382/85-26 | |||
DOCUMENTS REVIEWED | |||
TITLE REVISION DATE | |||
Nuclear Operations Management Manual (NOMM) | |||
Foreword and Policy Statement 0 3/18/85 | |||
Section I - Introduction 0 3/18/85 | |||
Section II - Mission and Goals 0 3/18/85 | |||
Section III - Management Documentation 0 3/18/85 | |||
Section IV - Quality Requirements Matrix 0 3/18/85 | |||
Section V - Nuclear Safety Quality Policies 0 3/18/85 | |||
Chapter 1 - Organization 0 3/18/85 | |||
Chapter 2 - Quality Assurance Program 0 3/18/85 | |||
Appendix B - Nuclear Safety Quality | |||
Policy Compliance With | |||
10 CFR 50, Appendix B 0 3/18/85 | |||
Section VI - Special Scope Quality Policies 0 3/18/85 | |||
Chapter 5 - Radioactive Waste Management 0 3/18/85 | |||
Attachment 1 - QA Program for | |||
Transport Packaging 0 3/18/85 | |||
Chapter 9 - ALARA Program 0 3/18/85 | |||
Chapter 10 - Radiation Protection 0 3/18/85 | |||
Quality Assurance Procedures (QAP) | |||
QAP-000, Quality Assurance Charter 0 6/10/85 | |||
QAP-001, Quality Assurance Group | |||
Requirement Matrix 0 6/10/85 | |||
i | |||
_ ._- | |||
. - | |||
2 | |||
QAP-003, Preparation and Revision of NOMM | |||
Sections IV, V, and VI 0 6/10/85 | |||
QAP-012, Corrective Action Requests 0 6/10/85 | |||
QAP-200, Scheduling of Vendor Quality | |||
Assurance Section Audits 0 6/10/85 | |||
QAP-302, Scheduling and Performing Operations | |||
, Surveillance Audits 0 6/10/85 | |||
QAP-303, Technical Specifications | |||
Surveillance Audits 0 6/10/85 | |||
Nuclear Services Procedures (NSP) | |||
NSP-241, Radiation Control Unit Organization | |||
and Responsibilities 1 4/11/85 | |||
NSP-246, Radiation Control Unit Plant | |||
Appraisals 2 6/10/85 | |||
NSP-247, Radiation Control Unit Radwaste | |||
Review 0 3/30/84 | |||
Health Physics Group Procedures (HP) | |||
HP-01-152, Marking, Handling, and Storage | |||
of Radioactive Material 3 2/26/85 | |||
HP-01-214, RCA Control Point Operation 2 10/10/84 | |||
Radioactive Waste Management Procedures (RW) | |||
RW-01-100, Radioactive Waste Reduction 1 1/9/85 | |||
RW-01-200, Record Preparation, Filing, & Storage 0 11/19/84 | |||
RW-01-210, Process Control Program 1 6/5/85 | |||
: | |||
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - | |||
c | |||
,, . | |||
* | |||
3 | |||
RW-01-400, Radioactive Waste Reduction | |||
Cost-Benefit Analysis 0 2/25/83 | |||
RW-02-100, Handling Dry Active Waste (DAW) | |||
and Used Protective Clothing 1 12/17/84 | |||
RW-02-110, Waste Sample Collection and | |||
Isotope Evaluation 1 10/16/84 | |||
RW-02-200, Packaging Radioactive Solid Waste | |||
(DAW) for Disposal 3 11/23/84 | |||
RW-02-210, Radioactive Waste Solidification 3 6/19/85 | |||
RW-02-220, Radwaste Filter Disposal 1 3/8/85 | |||
RW-02-230, Dry Waste Segregation 0 2/13/84 | |||
RW-02-231, Granulating Material for Disposal 0 3/16/84 | |||
RW-02-300, Receipt, Storage and Loading of | |||
Shipping Containers 1 7/16/85 | |||
RW-02-310, Storage of Loaded Shipping | |||
Containers 1 7/10/83 | |||
RW-02-320, Packaged Radioactive Waste Control | |||
and Inventory 2 12/7/84 | |||
RW-02-330, Radioactive Waste Tracking 0 11/19/84 | |||
RW-02-500, Radioactive Material Shipment 2 6/20/85 | |||
RW-02-800, Dose to Curie Conversion 0 1/8/85 | |||
RW-02-810, Waste Classification 0 1/7/85 | |||
RW-02-570, Receipt of Radioactive Material 1 7/10/83 | |||
Nuclear Training Department | |||
' | |||
UNT-3-018, Radwaste Helper and Radwaste | |||
Technician Training Procedure 1 5/1/84 | |||
1 | |||
TE-RW-01, Course Description - Radwaste | |||
l Helper Training 1 11/1/84 | |||
1 | |||
, | |||
i | |||
. _ . _ | |||
.. o | |||
4 | |||
. | |||
Radwaste Department Course Catalog 10/10/85 | |||
Lesson Plans: | |||
Dry Waste Segregation | |||
Radwaste Regulatory Awareness (CHEM NUC) | |||
Radwaste Program Overview | |||
Radioactive Solid Waste Compaction | |||
Radwaste Solidification | |||
Radwaste Helper Training Course | |||
Radioactive Material Packaging | |||
Marking, Labeling and Placarding | |||
Requirements for Radioactive Material | |||
Shipments | |||
Radioactive Shipping Papers | |||
Decontamination | |||
Radwaste Material Handling | |||
Radwaste Shipments | |||
, | |||
RADMAN Computer Software | |||
Other Documents | |||
Resume' of J. Etheridge 8/9/83 | |||
Position Description - Radwaste Engineer 0 4/3/84 | |||
Position Description - Radwaste Assocatte | |||
Engineer II/I 0 4/3/84 | |||
Position Description - Radwaste Supervisor | |||
(Support Services) 0 4/3/84 | |||
Position Description - Radwaste Supervisor | |||
(Transportation) 0 4/3/84 | |||
I | |||
.. , | |||
i 5 | |||
i | |||
, | |||
Position Description - Radwaste Technician 0 4/3/84 | |||
Position Description - Radwaste Helper 0 2/16/84 | |||
Letter, from LP&L Wuller, to file, Subject: | |||
Agreement on Generic Correspondence | |||
Between LP&L and Region IV NRC 9/25/85 | |||
i | |||
QA Audit Report SA-W3-QA-84-47 - HP and | |||
Radwaste Technician / Helper Training 1/16/85 | |||
QA Audit Report SA-W3-QA-85-12 - Radioactive | |||
Waste Management and Shipping 4/30/85 | |||
Nuclear Services Radiation Control Unit | |||
Appraisal of the WAT-3 HP and Radwaste Programs 7/18/85 | |||
Letter, from LP&P Kenning, to LP&L Rollins | |||
Subject: Response to HP and Radwaste | |||
Appraisal 85-2 9/25/85 | |||
Operations QA Audit Schedule for March 1985 through | |||
February 1987 8/21/85 | |||
Radioactive Waste Packaging Logs for 1985 | |||
LP&L Semiannual Radioactive Effluent Release Report 8/29/85 | |||
, | |||
}} |
Latest revision as of 19:54, 27 October 2020
ML20137W986 | |
Person / Time | |
---|---|
Site: | Waterford |
Issue date: | 11/29/1985 |
From: | Chaney H, Murray B, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20137W961 | List: |
References | |
50-382-85-26, IEB-79-19, NUDOCS 8512100391 | |
Download: ML20137W986 (17) | |
See also: IR 05000382/1985026
Text
m ,,
[; sY-. ,
.
APPENDIX C
U.S. NUCLEAR REGULATORY COMMISSION
,
REGION IV
-[ NRC Inspection Report: 50-382/85-26 License: NPF-38
. Docket: -50-382
Licensee: Louisiana Power & Light Company (LP&L)
ATTN: R. S. Leddick, Senior Vice President
Nuclear Operations
142 Delaronde Street
4
New Orleans, Louisiana 70174
Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)
Inspection At: Taft, St. Charles Parish, Louisiana (Wat-3 site) and
Generai Office in New Orleans, LA
. Inspection Conducted: October 7-11, 1985
'
Inspectors; n[- , / #-27-86
H.Chan'e9~,IT(did.igfSpecialist, Facilities Date
Radiological Prot %ction Section
,
du Ma,, //-Z7-d5
D. B. Spitzberif, ifadfation Specialist, - Date
Facilities Radiolobical Protection
-Section
~
,.i
A~
p proved: [//c 1/11tztd ///BW65
B. Murray, Chief,' Facilit/tes Radiological
~
i Dage /
'
Protection Section /
Inspection Summary
Inspection Conducted October 7-11, 1985 (Report 50-382/85-26)
.,
, Areas Inspected: Routine, unannounced inspection of the licensee's radioactive
material (RAM) shipment program, solid radioactive waste (radwaste) management
i
8512100391Bj0
ADOCK O
82
G
- _ _ _ _ _ __ _- _. _- _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ ~
-
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2
program, and activities involving onsite storage of low-level ' radioactive
waste (LLRW). The inspection involved 75 inspector-hours onsite and
7 inspector-hours offsite by two NRC inspectors.
Results: Within the areas inspected, two violations, (see paragraphs 4 and 5),
and one deviation (see paragraph 7) were identified.
s
.. o
3
DETAILS
1. Persons Contacted
LP&L-
-R.-Barkhurst, Plant Manager
- S. Alleman, Assistant Plant Manager
.
- R. Kenning, Radiation Protection Superintendent
- L. Simon, Radwaste Engineer
- K. Brewster, Licensing Engineer
- R. Cornell, Independent Safety Engineering Group, Engineer
- D._.'Stevens, Radwaste Supervisor
- M. Moe, Radwaste Supervisor
- D.~ Landeche, Health Physics (HP) Supervisor
- R. Pittman, Operation Quality Assurance (QA) Supervisor
- J. Woods, Quality Control (QC) Manager
'*D. Rieder, Radwaste Associate Engineer
-
.
'J. Etheridge,' LP&L General Office (GO), Radiation Control Unit,
Radwaste Engineer -
E. Fields, Engineering Nuclear' Safety, Engineer
J. Messina, QA-Representative
'G. Wuller, Onsite Licensing Coordinator
W. Perry, Chemistry and Radwaste Training Instructor
~J. O'Hern, General Training Superintendent
" Denotes those present at the exit interview on October 11, 1985.
The NRC inspector also interviewed several other licensee and contractor
personnel.
2. Licensee Actions on Previously Identified Inspection Findings
.(Closed).0 pen Item (382/8512-02): Pre-use Response Check for Radiation #
-Measurement Instruments --This item was previously discussed in NRC
Inspection Report 50-382/85-12 and_ involved the licensee's7 1ack of a
suitable pre-use response check for the Eberline teletector high range
probe. The licensee had implemented a revision to HP Directive 83-1 which
provided for response checking the high range probe of the teletector
prior to use. Several teletectors were inspected for documentation of the
required response check. This item is-considered closed.
3. Organization and Management Controls
The NRC inspectors reviewed the licensee's onsite and offsite organiza-
tions that were involved with RAM transportation, radwaste operations and
>
.
4
management to determine compliance with the commitments contained in the
Final Safety Analysis Report (FSAR), Sections 11,12, and 13; and the
requirements of the facility operating license Technical Specifications
(TS), Section 6; NRC Inspection & Enforcement (I&E) Bulletin 79-19, and
the recommendations in NRC Branch Technical Position (BTP) concerning
waste classification and characteristics.
The NRC inspectors determined that th radwaste organization agreed with
the organizational chart depicted in Figure 6.2-2 of the TS. The licensee
had developed position descriptions for personnel functional assignments-
and designated a specific individual as being responsible for LLRW and the
transportation of RAM.
The NRC inspectors reviewed procedures and a computerized program for LLRW
classification, characterization, and shipping document preparation. The
procedures reviewed are listed in the Attachment I to this report.
The NRC inspectors reviewed the licensee's Process Control Program (PCP),
the vendor's solidification PCP, and operating procedures. The NRC
inspectors discussed with the licensee the apparent lack of positive
control over vendor procedures used for solidification operations. This
item was also noted as a finding in a recent licensee QA audit
(SA-W3-QA-85-12). The licensee stated that actions were being taken to
place vendor procedures under their change and revision control. The
licensee was noted to have developed a special scope QA document (Nuclear
Operations Management Manual-NOMM,Section VI, Chapter 5) for general
radwaste management and the establishing of specific QA/QC policies for
compliance with 10 CFR Part 71, Subpart H requirements.
The NRC' inspectors reviewed the licensee's program for appraisals and
audits of transportation and radwaste activities. Recent audits and
appraisals (SA-W3-QA-84-47, SA-W3-0A-85-12, and RCU Appraisal 85-2) of
radwaste and transportation activities, including management and training
aspects w~re reviewed. The NRC inspectors noted that the licensee's
auditor checklists and audit notes were not of a sufficient depth to
ensure that all of the NOMM's directives had been implemented in the
radwaste program. The NRC inspectors also reviewed responses to audit
findings and the program for ensuring audit findings were resolved in a
timely manner. The NRC inspectors noted to the licensee at the exit
meeting that, currently, there are no personnel in the operations- QA audit
group with technical expertise in the field of radwaste and transportation-
activities. .The licensee stated that they are considering recruiting
personnel with HP,-radwaste/ transportation experience and that future
audits of radwaste activities would evaluate implementation of the
radwaste program.
No violations or deviations were identified.
-
.
5
4. Training and Qualification
The NRC inspectors reviewed the licensee's training and qualification
program for perscnnel assigned transportation and radwaste duties to
determine compliance with commitments contained in the FSAR, Section 13;
and the requirements of TS 6.3, 6.4; and I&E Bulletin 79-19, and the
recommendations of industry standards ANSI /ANS 3.1-1978 and
.
The NRC inspectors reviewed course' descriptions, lesson plans, personnel
training records, QA audits, and held discussions with training department
personnel. The NRC inspectors were informed by training department
personnel that the Institute of Nuclear Power Operation's (INPO)
accreditation program for training of plant personnel did not specifically
include radwaste activities involving transportation or the handling of
LLRW (compaction and solidification), and that current performance based
training development did not provide for task analysis in radwaste
functional areas. The NRC inspectors noted to the licensee that the NRC
would expect the licensee to maintain the training and retraining program
for radwaste activities.
The NRC inspectors reviewed the training qualifications of several rad-
waste group personnel that performed compaction of LLRW to determine
compliance with IE Bulletin 79-19 and licensee procedures. Radwaste
Technical Procedure RW-02-200, " Packaging Radioactive Solid Waste (DAW)
for Disposal," specifies that personnel performing compaction using the
B-100 compactor (large box type compactor) must have completed training in
the following areas:
- General Employee Training,
- Redwaste Training in accordance with UNT-03-018, "Radwaste Helper and
Radwaste Technician Training Procedure,"
-* Instruction in the operation of the B-100 waste compactor,
- The handling of radwaste in accordance with procedure RW-02-200, and
- Qualification training for forklift truck operation, including
demonstrating operating ability.
The NRC inspectors determined on October 10, 1985, that a contracted
employee had compacted DAW using the-B-100 compactor approximately 18
times,.during the period July 18 through September 5, 1985. Contrary to
the above requirements, licensee training records showed that out of the
five specific training courses referenced above, the contractor employee
_ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
m
.
6
had only received the General Employee training. Failure to conduct the
specified training is considered a violation of TS 6.8.1 (382/8526-02).
.The NRC inspectors reviewed Nuclear Training Department radwaste course
descriptions, lesson plans of completed courses, attendance rosters, and
tests. The NRC inspectors noted that, with the exception of the employee
noted above, all other employee's inspected (including contractor.
. personnel) were qualified for their functional area assignments.
No deviations were identified.
5. Radioactive Material Transportation Program
The NRC inspectors reviewed the licensee's transportation program for
compliance with the requirements of 10 CFR Part 71, and DOT regulations
49 CFR Parts 171 through 178, the NRC I&E Bulletin 79-19, commitments
contained in Sections 11.4.4 and 12.5.1.3 (K) and (1) of the FSAR, the
recommendations in I&E Notices 83-10, 84-14, and 84-50, NRC Regulatory
Guides (RGs) 7.1 through 7.10, and the guidance contained in NUREG-0923
and the licensee's commitments.
The NRC inspectors determined that since receiving their operating license
in December 1984 the licensee had not shipped any radioactive material
other than low specific activity (LSA) waste that did not exceed Type A
quantities. Therefore, only strong, tight containers have been used by
the licensee.for seven such shipments.
a. Quality Assurance Program and Audits
The NRC inspectors reviewed the licensee's QA program for compliance
with the requirements of 10 CFR Part 71, Subpart H. QA attributes
governing the procurement of packaging, use of packaging, and ship-
ment of RAM is set forth in Attachment I to Chapter 5 of Section VI
to the NOMM (see paragraph 3 above). This quality program satisfies
the requirements of 10 CFR Part 71.101(b). The licensee has also
notified the NRC concerning the requirements of 10 CFR Part 71.101(f).
A review of licensee procedures for the shipment of RAM showed the
extensive use of independent QC verifications and checklists for .
container loading and closing. The licensee's audits to date had
been conducted prior to the licensee shipping any RAM. However, the
<
licensee's radwaste contractor'had conducted an appraisal of RAM
shipping during June of this year and reviewed the radwaste
activities associated with one shipment and noted no deficiencies.
j.
,
,
-
7
b. Procedures .
The licensee's procedures for selection of packaging, preparation for
shipment, marking / labeling / placarding, mcnitoring for radiation and
contamination, and criteria for disposal site acceptance were
reviewed and found to be satisfactory except for the form used in
.RW-02-500, _.for determining the dose rate from a package for curie
content estimation. The NRC inspectors noted that the instructions
on the form were confusing and that values for average container dose
rates were in error on a majority of the shipments reviewed. The
. licensee's representatives stated that HP personnel filling out the-
-forms were making the errors due to the complexity of the forms and
insufficient training. The licensee representative further stated
that the data from the forms were not used to estimate the curie
content of containers previously shipped since the computerized RAM
shipping program for waste containers, utilized shipment specific
radicchemistry analysis results for determining each container's
curie content. The licensee stated at the exit meeting that the
subject form would the revised to make it simpler to use.
c. Procurement and Selection of Packagings
The licensee was found to have implemented detailed instructions on
the. procurement and receipt inspection of shipping con-
tainers /packagings. This included both DOT specification and NRC
certified packages.
The NRC inspectors noted during the period October 7 through 10 that
the licensee had stored approximately eight steel liners, used for
the solidification or dewatering of LLRW resins / wetted solids and as
LSA shipping containers, in an area which was not protected from
inclement weather. These containers / liners had been stored outside
of the security fence opposite the Services Building on the west side
of the plant. These storage conditions are contrary to the
requirements in procedure RW-02-300, " Receipt, Storage and Loading of
Shipping Containers," paragraph 6.1.1, which requires that all DOT
specification, strong, tight, and certified shipping containers shall
be stored to minimize exposure to inclement weather conditions.
Failure to provide proper storage is considered a violation of
TS 6.8.1 (382/8526-01).
d. Determination of Package Activity and Radionuclides
The NRC inspectors reviewed the licensee's methodologies for deter-
mining the curie content of packages. The licensee's computerized
radwaste management program (RADMAN) provides for establishing a
,
containers curie content by either direct input of quantitative
radiochemistry analyses or by a default program using generic PWR
s
.
8
waste stream radionuclide concentrations and a dose rate to curie
estimation based on Rockwell International shielding methodologies.
-The licensee currently uses the method of directly inserting quantita-
tive radiochemistry analyses into the data base of each shipment. As
noted in paragraph 5.b above, the licensee is reevaluating the
current dose rate averaging method for packages.
e. Preparation of Packages for Shipping
The NRC inspectors reviewed the licensee's procedures for the receipt
inspection, opening, loading and closure of shipping containers and
casks. The NRC inspectors discussed with licensee representatives
the QC inspections set forth in shipment preparation procedures and
the expected degree of-QC involvement in each shipment.
Plant proc.edure RW-2310, Revision 1, " Storage of Loaded Shipping
Containers," paragraph 6.2, requires all loaded shipping containers
to be stored in weather tight buildings or enclosures. The NRC
inspectors determined on October 10, 1985, that the licensee had
stored approximately 114 filled LSA strong, tight shipping containers
(22 solidification liners and 92 steel, B-25 shipping containers)
outside in an area exposed to ambient whether conditions. This is a
second example.of failure to provide proper storage for materials
important to quality and is an apparent violation of T.S. 6.8.1 and
station procedures (382/8526-01-see paragraph 5.c above).
The NRC inspectors noted that many of the containers (B-25 steel
boxes) were filled with condensate polisher resins, which involved
low-level radioactive contamination for which the licensee is
petitioning the NRC to allow onsite burial per-10 CFR Part 20.302
criteria. The NRC inspectors also noted that the B-25 containers
have been accumulating since the April 1985 incident involving a
primary to secondary leak, Licensee Event Report No. 85-13, and that.
there was no program / procedure for the periodic inspection of the
containers' physical condition.
f. Delivery of Packages to Carriers
The NRC inspectors reviewed the licensee's shipping documents for the
eight RAM shipments made by the licensee since the start of facility
operations. The documents were reviewed for content and accuracy
concerning DOT proper shipping name, hazard classification, hazard
identification number, listing of radionuclide inventory, description
of contents (physical and chemical), curie content, category of
labels applied to the package, determination of DOT transport index
val ~ue, placarding applied to the transport vehicle, and whether any
chelating agents were present in LLRW. The licensee's shipping
- . _ - - _ _ - _ - - - - - - _ _ - -
'
,
.
.
9
documents indicate that past packages delivered to carriers satisfied
the requirement of 49 CFR Parts 100 through 177, and those of 10 CFR
Part 20.311.
g. Receipt of Packages
The NRC inspectors reviewed the licensee's procedures and records for
receipt of radioactive material and determined that the requirements-
of 10 CFR Part 20.205 and recommendations of RG 7.'s were being met.
h '. ' Transportation Incidents.
The NRC inspectors determined,'by discussions with licensee representa-
tives, that none of LP&L's RAM shipments had been involved in accidents
or incidents. Also, no violations have been noted on RAM received.
i. Records, Reports, and Notifications
The NRC inspectors reviewed the licensee's procedures and records for
RAM shipments. The NRC inspectors noted to the licensee that there
appeared to be insufficient independent review of the entire shipping
document package prior to package shipment. The licensee stated that
this aspect of the program would be looked into for possible improve-
ment. The licensee's shipment notification program appears to
satisfy the requirements of 10 CFR Part 71.89.
No' deviations'were noted.
6. Low-Level Radioactive Waste Management Program
The NRC inspectors reviewed the licensee's program for the control,
classification, characterization, and shipment of low-level radioactive
waste to' determine compliance with the commitments contained in
-Section 11.4 of the FSAR; and the requirements contained in 10 CFR
Parts 20.301, 311, 61.55, and 61.56; and TS 6.5.1.6.n, 6.8.1.1, 6.13,
and 6.15; and the recommendations of NRC BTP papers on LLRW classification
and waste form,
a. Procedures
The NRC inspectors reviewed the licensee's process control program
procedure, implementation of the RADMAN computerized LLRW management-
system (including the internal programs for LLRW shipment tracking,
waste manifest preparation, waste classification, and curie content
estimation), QA and G0 audits of LLRW activities, plant waste stream
sampling and analysis procedures, and implementation of the LDCL
Special Scope QA program for radwaste activities.
'
.
10
b. Sampling and Analysis
The NRC inspectors reviewed the licensee's scaling factors program
for the inventory of radionuclides. This generic model is based on
several Combustion Engineering type pressurized water reactors. The
NRC inspectors discussed with licensee representatives the licensee's
future plans on periodic sampling of waste streams and the developing
of plant specific scaling factors. The licensee's planned program
includes semiannual sampling of waste streams with analyses by an
offsite laboratory in conjunction with quarterly samples analyzed by
the onsite radiochemistry group.
c. Effluent Release and Controls
The NRC inspectors reviewed the licensee's controls over the release
of RAM to unrestricted areas. The licensee had implemented personnel
training (general employee and radiation worker), and detailed
procedures for the handling, control and surveying of potentially
contaminated material. The licensee's controls, equipment, and
procedures were reviewed, as well as actual processing of potenti-
ally contaminated materials by HP personnel. The NRC inspectors
discussed with licensee representatives the NRC's position on use of
state-of-the-art radioactivity measurement equipment for evaluating
the radiological status of materials being released from licensee
control. The NRC inspectors emphasized to the licensee the restrict-
ions placed on 10 CFR Part 50 licensees concerning release of
radioactive material as discussed in NRC I&E Information Notice
No. 83-05.
The licensee informed the NRC inspectors that they were pursuing a
petition to the NRC for establishing an onsite waste burial facility
for the disposal of very low-level radioactively contaminated con-
densate polisher resins per 10 CFR Part 20.302 and the guidance
contained in the above noted I&E Information Notice.
d. Operations and Maintenance of Facilities and Equipment
lhe NRC inspectors determined that the licensee had elected not to
use the installed plant solidification system, but was using a vendor
provided and operated solidification system. The vendor's PCP and
procedures have been accepted by the NRC as meeting the requirements
of 10 CFR Part 61.56. Due to the licensee's nonradiological
limitations on boron in discharged liquids from the plant, the
licensee is utilizing a supplemental demineralizer system (vendor
provided and operated) for treatment of waste liquids. The licensee
had provided for the continuous monitoring of airborne radioactivity
within the temporary solidification facility and specific work area
grab sampling during solidification activities; also the licensee had
provided monitoring instrumentation and HEPA filtered ventilation
- - - _ _ _ .
-
.
11
system for the waste segregation and compaction facility. The
licensee also stated that revisions to the FSAR, Section 11.4.8.1
were being planned to resolve the description inaccuracies concerning
the ventilation system on the DAW waste compactor. The licensee's
actions noted above resolve the NRC's. concerns about the temporary
solidification facility and the waste compaction building which were
discusseo in NRC Inspection Report 50-382/84-38.
e. Reports
The NRC inspectors reviewed the licensee's semiannual Radioactive
Effluent Release Report, documented changes to the solid radwaste
system, and PCP procedure changes submitted to the NRC per TS 6.9.1.8
for the period March 4 (initial criticality) through June 30, 1985.
Since issuance of an operating license in December 1984 the
licensee's LLRW inventory has been:
LLRW in
Shipments LLRW to be Long Term
Types of LLRW To Burial Shipped Storage
DAW 950 ft' 190 ft2 none
Wetted Wastes 3094 ft' 1092 ft' 8155 ft'*
- Denotes waste being held pending 10 CFR Part 20.302 determination.
7. Onsite Low-Level Radioactive Waste Storage
The' licensee's onsite low-level radioactive waste storage facilities were
reviewed for agreement with the guidance provided in NRC Generic
Letter 81-38, and the licensee's commitments contained in Sections 11.4.6
and 11.4.7 of the FSAR.
The NRC inspectors determined that the licensee had developed. plans and
selected a building site for an interim LLRW storage and DAW compaction
facility of approximately 24,000 square feet. The scheduling for start'of
construction is being held in abeyance pending the outcome of state burial
site compact negotiations and federal legislation'on keeping existing
burial sites open. The licensee's plans appear to incorporate all the
design aspects discussed in the NRC Generic Letter, and NRC BTP-ETSB'11-3.
The FSAR in Sections 11.4.6, 11.4.7, and 11.4.8 identifies LLRW storage
areas in the following locations:
a. Reactor Auxiliary Building Solidification Facility (11.4.6),
_---_4
c
,
12 .
b. An outside lay down area (concrete slab) on the east side of the dry
cooling towers (11.4.7), and
c. Interim Dry Compacted Waste Facility (11.4.8).
The NRC inspectors determined on October 10, 1985, that the licensee had
established approximately four additional LLRW storage areas other than
those referenced in the FSAR. The licensee had established storage for
a;. proximately 114 filled LLRW shipping containers in 4 additional areas of
the plant as follows:
West side of the turbine building (approximately 71 containers),
- Southwest corner of the switchyard fence (approximately 19
containers),
East side of the switchyard fence (approximately 2 containers), and
. East side of the turbine building (approximately 22 containers).
The use of additional LLRW storage areas is considered a Deviation of
Commitments in the FSAR (382/8526-01).
8. Exit Interview
The NRC inspectors met with the licensee's representatives identified in
paragraph 1 of this report at the conclusion of the inspection on
October 11, 1985. The NRC inspectors summarized the scope and the results
of the inspection. In response to the inspectors comments and concerns
the licensee provided the following commitments:
a. More positive control will be exercised over vendor procedures used
in the LLRW processing program,
b. The forms and methodologies for determining dose rate information
used in RAM shipment curie estimation will be reevaluated.
c. An independent review program will be implemented concerning the
completed RAM shipment dccument packages.
_ _ - _
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ATTACHMENT 1
TO NRC INSPECTION REPORT
50-382/85-26
DOCUMENTS REVIEWED
TITLE REVISION DATE
Nuclear Operations Management Manual (NOMM)
Foreword and Policy Statement 0 3/18/85
Section I - Introduction 0 3/18/85
Section II - Mission and Goals 0 3/18/85
Section III - Management Documentation 0 3/18/85
Section IV - Quality Requirements Matrix 0 3/18/85
Section V - Nuclear Safety Quality Policies 0 3/18/85
Chapter 1 - Organization 0 3/18/85
Chapter 2 - Quality Assurance Program 0 3/18/85
Appendix B - Nuclear Safety Quality
Policy Compliance With
10 CFR 50, Appendix B 0 3/18/85
Section VI - Special Scope Quality Policies 0 3/18/85
Chapter 5 - Radioactive Waste Management 0 3/18/85
Attachment 1 - QA Program for
Transport Packaging 0 3/18/85
Chapter 9 - ALARA Program 0 3/18/85
Chapter 10 - Radiation Protection 0 3/18/85
Quality Assurance Procedures (QAP)
QAP-000, Quality Assurance Charter 0 6/10/85
QAP-001, Quality Assurance Group
Requirement Matrix 0 6/10/85
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2
QAP-003, Preparation and Revision of NOMM
Sections IV, V, and VI 0 6/10/85
QAP-012, Corrective Action Requests 0 6/10/85
QAP-200, Scheduling of Vendor Quality
Assurance Section Audits 0 6/10/85
QAP-302, Scheduling and Performing Operations
, Surveillance Audits 0 6/10/85
QAP-303, Technical Specifications
Surveillance Audits 0 6/10/85
Nuclear Services Procedures (NSP)
NSP-241, Radiation Control Unit Organization
and Responsibilities 1 4/11/85
NSP-246, Radiation Control Unit Plant
Appraisals 2 6/10/85
NSP-247, Radiation Control Unit Radwaste
Review 0 3/30/84
Health Physics Group Procedures (HP)
HP-01-152, Marking, Handling, and Storage
of Radioactive Material 3 2/26/85
HP-01-214, RCA Control Point Operation 2 10/10/84
Radioactive Waste Management Procedures (RW)
RW-01-100, Radioactive Waste Reduction 1 1/9/85
RW-01-200, Record Preparation, Filing, & Storage 0 11/19/84
RW-01-210, Process Control Program 1 6/5/85
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
c
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3
RW-01-400, Radioactive Waste Reduction
Cost-Benefit Analysis 0 2/25/83
RW-02-100, Handling Dry Active Waste (DAW)
and Used Protective Clothing 1 12/17/84
RW-02-110, Waste Sample Collection and
Isotope Evaluation 1 10/16/84
RW-02-200, Packaging Radioactive Solid Waste
(DAW) for Disposal 3 11/23/84
RW-02-210, Radioactive Waste Solidification 3 6/19/85
RW-02-220, Radwaste Filter Disposal 1 3/8/85
RW-02-230, Dry Waste Segregation 0 2/13/84
RW-02-231, Granulating Material for Disposal 0 3/16/84
RW-02-300, Receipt, Storage and Loading of
Shipping Containers 1 7/16/85
RW-02-310, Storage of Loaded Shipping
Containers 1 7/10/83
RW-02-320, Packaged Radioactive Waste Control
and Inventory 2 12/7/84
RW-02-330, Radioactive Waste Tracking 0 11/19/84
RW-02-500, Radioactive Material Shipment 2 6/20/85
RW-02-800, Dose to Curie Conversion 0 1/8/85
RW-02-810, Waste Classification 0 1/7/85
RW-02-570, Receipt of Radioactive Material 1 7/10/83
Nuclear Training Department
'
UNT-3-018, Radwaste Helper and Radwaste
Technician Training Procedure 1 5/1/84
1
TE-RW-01, Course Description - Radwaste
l Helper Training 1 11/1/84
1
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4
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Radwaste Department Course Catalog 10/10/85
Lesson Plans:
Dry Waste Segregation
Radwaste Regulatory Awareness (CHEM NUC)
Radwaste Program Overview
Radioactive Solid Waste Compaction
Radwaste Solidification
Radwaste Helper Training Course
Radioactive Material Packaging
Marking, Labeling and Placarding
Requirements for Radioactive Material
Shipments
Radioactive Shipping Papers
Decontamination
Radwaste Material Handling
Radwaste Shipments
,
RADMAN Computer Software
Other Documents
Resume' of J. Etheridge 8/9/83
Position Description - Radwaste Engineer 0 4/3/84
Position Description - Radwaste Assocatte
Engineer II/I 0 4/3/84
Position Description - Radwaste Supervisor
(Support Services) 0 4/3/84
Position Description - Radwaste Supervisor
(Transportation) 0 4/3/84
I
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i 5
i
,
Position Description - Radwaste Technician 0 4/3/84
Position Description - Radwaste Helper 0 2/16/84
Letter, from LP&L Wuller, to file, Subject:
Agreement on Generic Correspondence
Between LP&L and Region IV NRC 9/25/85
i
QA Audit Report SA-W3-QA-84-47 - HP and
Radwaste Technician / Helper Training 1/16/85
QA Audit Report SA-W3-QA-85-12 - Radioactive
Waste Management and Shipping 4/30/85
Nuclear Services Radiation Control Unit
Appraisal of the WAT-3 HP and Radwaste Programs 7/18/85
Letter, from LP&P Kenning, to LP&L Rollins
Subject: Response to HP and Radwaste
Appraisal 85-2 9/25/85
Operations QA Audit Schedule for March 1985 through
February 1987 8/21/85
Radioactive Waste Packaging Logs for 1985
LP&L Semiannual Radioactive Effluent Release Report 8/29/85
,