IR 05000498/1999001

Insp Repts 50-498/99-01 & 50-499/99-01 on 990104-07.No Violations Noted.Major Areas Inspected:Insp Reviewed Implementation of Solid Radwaste Mgt & Radioactive Matl Transportation Programs & Plant Support

ML20203C154
Person / Time
Site:	South Texas
Issue date:	01/27/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20203C150	List: IR 05000498/1999001 ML20203C144
References
50-498-99-01, 50-498-99-1, 50-499-99-01, 50-499-99-1, NUDOCS 9902110231
Download: ML20203C154 (11)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-498 50-499 License Nos.: NPF-76 NPF-80 Report No.: 50-498/99-01 50-499/99-01'

Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas Dates: January 4-7,1999 inspector (s): J. Blair Nicholas, Ph.D., Senior Radiation Specialist Michael C. Hay, Radiation Specialist Approved By: Arthur T. Howell 111, Director Division of Reactor Safety Attachment: Supplemental information

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9902110231 990127 PDR G ADOCK 05000498 pg i

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-2-l EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report No. 50-498/99-01; 50-499/99-01 This announced, routine inspection reviewed the implementation of the solid radioactive waste  :

management and radioactive materials transportation program Plant Support

• Overall, an effective solid radioactive waste management program was implerante )

Waste stream sampling and analyses met procedural and regulatory requirement !

Solid radioactive waste was properly classified and characterized for shipment and disposal. Good facilities were maintained for the processing, storage, and management l of solid radioactive wastes. Housekeeping in the mechanical auxiliary buildings, l including the solid radioactive waste processing and storage areas, was very goo J These areas were free of debris, and containers of radioactive waste and materials were -

properly stored. Minor deficiencies involving degraded radioactive material container j labels and inventory tracking discrepancies pertaining to hazardous material containers j were identified. These deficiencies were promptly corrected and documented in the j licensee's corrective action program (Section R1,1).

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• A good transportation program for radioactive waste / material was maintaine )

Packages for shipping radioactive waste / material were properly prepared and documented (Section R1.2).

• Procedures and checklists established to implement the solid radioactive waste ,

management and transportation programs provided proper guidance for the handling,  !

processing, and shipping of radioactive waste / materials (Section R3). i

• Personnel involved in the trar,sfer, packaging, and shipment of radioactive waste / material were properly trained and qualified (Section R5).

• Appropriate staffing was maintained to implement the solid radioactive waste management and transportation programs (Section R6)

• An effective quality assurance program was in place. Quality asvance monitoring reports and a comprehensive health physics division self assessment were considered programmatic strengths. The licensee properly assessed and captured findings, observations, and recommendations from the self assessment in the corrective action program. No negative trends were identified during the review of solid radioactive waste 1 and transportation condition reports (Section R7). l l

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t l -3-l- ReDort Details IV. Plant SuDDort R1 Radiological Protection and Chemistry Controls R1.1 lmolementation of the Solid Radioactive Waste Proaram Inspection Scope (86750)

The inspectors interviewed licensee personnel and_ reviewed the following: ,

• Waste stream sampling results and waste characterization documentation

Scaling factors for required isotopes not measured directly

• Waste shipment manifests

Sluicing of spent resin into a high integrity container

Waste storage and container accountability

• Annual radioactive effluent and solid radioactive waste reports Observations and Findinas The inspectors verified that waste stream samples were taken as required and analyzed to meet 10 CFR Part 61 requirements for waste classification and characterizatio Waste streams analyzed were representative of waste generated and were properly ,

analyzed by a contractor laborator ,

i Classification of waste was performed with a com. outer code used in the nuclear industry.- Scaling factors for difficult to measure nbd.das in the waste streams were determined and upoetad as needed in the radwaste compder data base. The inspectors performed independent cabulations and verified thd selected )

! waste / materials shipments were properly characterized, classifieo, and shipped in the

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proper containers. Selected waste shipment manifests were reviewed, a.;d no problems were note l l The inspectors observed the sluicing of resin from the low activity spent resin storage l l tank to a high integrity container in'the Unit 1 truck bay. Continuous health physics j coverage was observed in the truck bay during the sluicing of the resin. Proper control

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and mdiological postings were established, and good ALARA and safety practices were l

noted. The sluicing of the resin was performed according to approved procedures

, resulting in minimal radiation exposure to the workers involved in the tas l i (- The inspectors toured areas in the mechanical auxiliary buildings and outside storage yards where radioactive waste / materials were handled, stored, and processed. The

radioactive waste processing and storage facilities were well maintained, properly posted, and controlled. Housekeeping in these areas was very good. The areas were free of debris and,in general, containers of radioactive v'aste and materials were 1 properly labeled and stored. However, on January 7,1999, the inspectors noted that

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-4-several radioactive material labels attached to radioactive material storage containers (B-25 boxes containing thermolag) located in the Unit 1 west radwaste storage yard were badly faded and the writing on several of the labels was not legible due to weathering conditions. The licensee took prompt and appropriate corrective actions including relabeling the appropriate containers. On January 7,1999, the licensee wrote Condition Report 99-307 documenting this issu Using a licensee supplied inventory list of stored radioactive waste containers, the inspectors verified the licensee's container accountability and storage locations. During the inventory verification, it was noted that the stored radioactive waste containers did not have identifying tracking numbers on each of the containers; therefore, only the number of containers in the various storage locations could be verified. The inspectors also noted that there were 19 drums of reactor coolant pump waste oilin the Unit 2 hazmat building instead of 17 that were listed on the inventory list provided to the l inspectors. The licensee took prompt corrective actions including writing identifying I tracking numbers on each of the containers, updating the inventory list, and initiating l Condition Report 99-31 A review of the annual radioactive effluent release report for 1997 revealed that the report contained the required solid radioactive waste dat ,

I Conclusions i

Overall, an effective solid radioactive waste management program was implemente Waste stream sampling and analyses met procedural and regulatory requirement Solid radioactive waste was properly classified and characterized for shipment and disposal. Good facilities were maintained for the processing, storage, and management of solid radioactive wastes and transportation activities. Housekeeping in the mechanical auxiliary buildings, including the solid radioactive waste processing and storage areas, was very good. These areas were free of debris, and containers of radioactive waste and material were properly stored. Minor deficiencies involving degraded radioactive material container labels and inventory tracking discrepancies pertaining to hazardous material containers were identified. These deficiencies were promptly corrected and documented in the licensee's corrective action progra R1.2 Transportation of Radioactive Material and Radioactive Waste Insoection Scope (86750)

The inspectors interviewed licensee personnel and reviewed selected exar ples of the following:

= Shipping documentation for radioactive waste / material shipments

= Radiation and contamination surveys of packages and vehicles

- Certificates of compliance for NRC-certified shipping casks

= Copies of current licenses for recipients of radioactive waste / material

= Package marking ad labeling

= Vehicle placarding

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• ~ Notifications to state agencies

• Emergency response information i

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~ b. Observations and Findinos

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No shipments of radioactive material or radioactive waste were made during the week of the inspection; therefore, no observations of actual shipment preparation were possibl A vendor supplied radwaste computer program was used to determine proper radioactive material transportation categories, shipping package labeling, and the ,

generation of shipping papers. Revisions to the radwaste computer program were ,

properly quality controlled and tested prior to installation and implementatio The inspectors retiewed selected shipping records for shipments of radioactive waste / material to verify compliance with Department of Transportation and NRC requirements. Radiation survey shipment records reviewed documented that radiation and contamination levels were within regulatory limits. The licensee maintained ,

photographs of radioactive waste shipments to document that shipments were labeled, i marked, and placarded properly. Correct emergency telephone numbers and detailed i emergency instructions were included with the shipping papers. State officials were J properly notified prior to radioactive waste shipments entering their states in accordance with regulatory requirements. The inspectors verified that Certificates of Compliance for routinely used Type B shipping casks were current and that the licensee was a registered user for the NRC-certified shipping casks used.' State shipping permits were j verified to be current. The inspectors verified that the licensee maletained on file current i copies of consignees' radioactive material hcense !

l Conclusions )

l A good transportation program for radioactive waste / material was maintaine Packages for shipping radioactive waste / material were properly prepared and documente R3' Radiological Protection and Chemistry Procedures and Documentation I I Inspection Scocel86750)

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The inspectors reviewed the procedures used to implement the solid radioactive waste management and transportation program Observations and Findin_m i

The irspectors noted that proper guidance was provided in the radwaste procedures for )

radiorctive waste stream sampling and analyses and preparing radioactive wastehaerial for shipment. For example, detailed procedures including checklists l were used for the preparation of radioactive waste / material shipment l

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-6- Conclusions Procedures and checklists established to implement the solid radioactive waste management and transportation programs provided proper guidance for the handling, processing, and shipping of radioactive waste / material R4 Staff Knowledge and Performance Through interviews with personnel responsible for implementing the solid radioactive ,

waste management program and observations of their performance of radioactive waste / material shipping activities, the inspectors determined that the health physics staff ,

was experienced and had an excellent working knowledge of the transportation 1 regulation R5 Staff Training and Qualifications Inspection Scooe (86750)

l The inspectors reviewed the training and qualification requirements of personnel )

l responsible for the preparation and packaging of radioactive waste and radioactive  ;

material for shipment. The inspectors reviewed the following items

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Continuing trainina program l * Training materials related to 49 CFR Parts 171-179 and 10 CFR Part 71

Personnel training and qualification records Observations and Findinas The inspectors verified that personnel training records documented that the health physics staff assigned the responsibility to implement the solid radioactive waste processing and transportation activities were properly trained. Vendor training courses provided annual retraining of personnel directly involved in the processing and shipping of radioactive materials and radioactive wast The inspectors verified that plant operators involved in the sluicing of resin to high integrity containers and contractor radwaste/decon personnel involved with handling and j loading of radioactive materials and waste for shipment were appropriately trained.

, Conclusions Personnel involved in the transfer, packaging, and shipment of radioactive waste / material were properly trained and qualifie R6- Radiological Protection and Chemistry Organization and Administration The health physics division's organization and staffing for the implementation of the solid radioactive waste management and transportation programs were reviewed. Since l

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x -7-the last NRC inspection of this area conducted in July 1997 several changes were noted. The health physics division manager was replaced in May 1998. In March 1998 the new supervisor position of the technical assistant team was filled to support the solid radioactive waste management and transportation programs. Also, the health physicist for radwaste technical support was replaced. These staffing changes did not degrade the effectiveness of the solid radioactive waste management and transportation programs performance. The inspectors noted that the two health physics technicians primarily responsible for radwaste processing and shipping activities remained the same since the previous NRC inspection and provided continuity and experience. Appropriate staffing was maintained to implement the solid radioactive waste management and transportation program R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Solid Radioactive Waste and Transportation Proaram Assessments Inspection Scope (86750)

The following items were reviewed to evaluate the licensee's effectiveness at identifying and correcting problems:

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• Training and qualifications of auditors i

• B:ennial quality assurance audit

• Department self assessments 4 l * Quality assurance monitoring reports l l * Vendor audits 1 i

' Observations and Findinas Auditsand Self Assessments

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No biennial quality assurance audit of the radiological controls /radwaste program had been conducted since the previous NRC inspection conducted in July 1997. The next radiological controls /radwaste audit is scheduled to start on January 25,1999. The 4

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qualifications, experience, and training of the acting lead auditor assigned to the scheduled radiological controls /radwaste program audit were reviewed. The auditor did L not have much technical and practical experience in solid radioactive waste

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management and transportation activities, and the auditor had not received training in the currently revised transportation regulations. The auditor's experience and training was discussed with station management, and it was agreed that the audit team for the scheduled audit willinclude a technical specialist experienced in and knowledgeable of l solid radioactive waste management and transportation program The inspectors reviewed 12 quality assurance monitoring reports of radwaste processing and transportation activities performed between May 1997 and December 1998. The monitoring reports documented quahty assurance oversight of various solid l radioactive waste processing and transportation activities including loading of sealand :

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8-containers with dry active waste, sluicing of spent resin into high integrity containers, transferring filled high integrity containers into shipping casks, and the preparation of radioactive waste shipments. The quality assurance monitoring reports were considered a programmatic evaluation strengt A health physics division self assessment conducted in October 1997 was reviewe The assessment was comprehensive, identifying one finding,18 observations, and 21 recommendations. The assessment's finding, observations, and recommendations were consolidated and addressed as action items in Condition Report 97-19651. The condition report contained 13 action items to be evaluated and corrected. At the time of the inspection, ten of the action items were closed with appropriate corrective actions taken, and the remaining three action items were in the process of being close Contractors were used to provide radwaste disposal service 1 and radiochemistry analyses of radwaste samples for 10 CFR Part 61 waste clas sification and characterization requirements. The inspectors reviewed the nuclear procurement issues committee audits of the contractors and identified no problerr.s. These contractors were ,

currently maintained on the licensee's authorized vendor's lis l I

Condition Reports l The inspectors reviewed selected solid radwaste and transportation condition reports I I

written since July 1997 and noted that the licensee identified issues at the proper threshold, in general, corrective actions were completed in a timely manner and appeared to be effective to correct the identified issues. The inspectors identified no negative trends during the revie ] Conclusions Overall, an effective quality assurance program was in place. Quality assurance monitoring reports and a comprehensive health physics division self assessment were considered programmatic strengths. The licensee properly assessed and captured i findings, observations, and recommendations from the self assessment in the corrective action program. No negative trends were identified during the review of the licensee's corrective action proces R8 Miscellaneous Radioloaical and Chemistry issues R8.1 (Closed) Violation 98020-01: Failure to Survev The inspectors determined the licensee's evaluation and corrective actions identified in Condition Report 98-17892 were appropriate. No additional similar violations were identifie .

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V. Manaaement Meetinas i X1 Exit Meeting Summary - *

The inspectors presented the inspection results to rnembers of licensee management at an exit meeting on January 7,1999. The licensee acknowledged the findings presented. No proprietary information was identifie i i

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee B. Bullard, Supervisor, Health Physics Division -

T. Cloninger, Vice President, Engineering and Technical Services '

J. Groth, Vice President, Nuclear Generation S. Head, Supervisor, Licensing S. Horak, Quality Specialist, Quality Assurance K. Kleinhans, Senior Health Physics Technician R. Masse, Plant Manager Unit 2 M. McBurnett, Director, Licensing and Quality  ;

B. Mookhoek, Licensing Engineer '

G. Powell, Manager, Health Physics Division j M. Rejcek, Consulting Engineer, Chemistry  ;

J. Sherwood, Supervisor, Rad Services Team I M. Smith, Manager, Plant Support Quality W. Smith, Senior Health Physics Technician G. Williams, Health Physicist 1 NRC N. O'Keefe, Senior Resident inspector I

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LIST OF INSPECTION PROCEDURES USED

IP 86750 ' Solid Waste Management and Transportation of Radioactive Wast LIST OF OPENED, CLOSED, AND DISCUSSED ITEMS Closed 50-499/98020-01 VIO Failure to Survey l

l LIST OF DOCUMENTS REVIEWED l Oraanization Charts I Health Physics Division - January 1999

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Quality Assurance Documents ,

Selected Quality Monitoring Reports from July 1997 through December 1998 Internal Assessment of the Radioactive Waste and Materials Shipping / Management Program, December 16,1997 l

Quality Surveillance Report 98-047," Radiological Controls Annual Review," September 17, ,

1998- ,

NUPlc Joint Quality Assurance Audit of Scientific Ecology Group, conducted August 3-6,1998 Vendor Quality Assurance Audit of Duke Engineering & Services Environmental Laboratory, conducted March 24-26,199 Procedures OPOP01-ZA-0001 " Plant Audits," Revision 2 i

OPOP01-ZA-0015 " Oversight Planning and Scheduling Process," Revision 5 {

OPRP03-ZR-001 " Determination of Radioactive Material Curie Content, Reportability, DOT Sub-Type and Waste Classification," Revision 5  ;

i OPRP03-ZR-002 " Radioactive Waste Shipments," Revision 10 j i

OPRP03-ZR-0010 " Dry Active Waste Operations," Revision 5 i OPRP03-ZR-0011 " Shipment of Radioactive Material," Revision 3 Miscellaneous Documents l Annual Operating Radioactive Effluent Report - 1997

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