IR 05000361/1997010

Insp Repts 50-361/97-10 & 50-362/97-10 on 970421-25.No Violations Noted.Major Areas Inspected:Review of Solid,Radioactive Waste Mgt & Radioactive Matls Transportation Programs

ML20141H171
Person / Time
Site:	San Onofre
Issue date:	05/19/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141H169	List: IR 05000361/1997010 ML20141H162
References
50-361-97-10, 50-362-97-10, NUDOCS 9705230209
Download: ML20141H171 (12)

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ENCLOSURE I'

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U.S. NUCLEAR REGULATORY COMMISSION .

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Docket Nos.: 50-361 50-362 License Nos.: NPF-10 -

NPF-15 Report No.: 50-361/97-10 50 362/97-10 Licensee:- Southern California Edison C I Facility: San Onofre Nuclear Generating Station, Units 2 and 3 L Location: 5000 S. Pacific Coast Hw .

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San Clemente, California i i

l Dates: April 21-25,1997 l

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Inspector: Thomas H. Andrews Jr., Radiation Specialist i i  :

j Approved By: Blaine Murray, Chief, Plant Support Branch' '

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l ATTACHMENT: Supplemental Information  !

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'9705230209 970519 PDR ADOCK O '300361 1' G PDR g L-

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l i i l 2-l l EXECUTIVE SUMMARY i l

San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361;-362/97-10 This announced, routine inspection reviewed the implementation of the solid, radioactive waste management and the radioactive materials transportation programs. Training, quality assurance oversight, and procedural guidance were also reviewe Plant Support i

e Shipments of radioactive materials were made consistent with revised Department of Transportation and NRC regulations (Section R1.1).

• The licensee's capability to respond to an emergency involving the transportation of radioactive materials was exceptionally good (Section R1.2).

• The licensee's procedure provided adequate guidance for shipment of radioactive i materials (Section R3).

• Personnel responsible for shipment of radioactive materials were trained consistent with the licensee's commitments (Section 5.1).

! * Personnel in the radioactive materials control group who performed shipping of radioactive materials were properly trained. An inspection followup item was opened related to training of personnel who assist the radioactive material control group during packaging, handling, and transport of radioactive materials (Section 5.2).

• The licensee assessments of the radioactive material control program were performed by personnel who were qualified according to the licensee's procedures, however, documented training was not provided related to the changes to the Department of Transportation and NRC regulations (Section 7.1).  :

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• The training and checklist for personnel performing inspection of transport vehicles l

was outstanding (Section 7.2). '

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Reoort Details IV. Plant Support 1

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R1 Radiological Protection and Chemistry Controls i R1.1 Shioments of Radioactive Materials  !

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! insoection Scoce (86750)  !

i i l The inspector toured areas of the plant where radioactive mataris;. were handled, i l' stored and processed, and reviewed shipping packages for several radpactive j

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material shipments to determine if the ' licensee. satisfied the applicable Department of Transportation and NRC requirements for shipment {

Observations and Findinos . }

l During the tour, the inspector observed that the licensee maintained an inventory of - i i empty drums. Based upon a recent industry experience where a coating used in a ;

l spent fuel cask reacted with boric acid to form hydrogen, the inspector questioned i the composition of the coating used in some of the drums. The licensee provided '

l information that demonstrated that the coating used 'in the drums was a different l l type not subject to this phenomeno The inspector reviewed shipping papers for several different shipments made since

! April 1,1996. Special attention was given to classification, characterization, ,

communications, and use of the proper units of measure. There were no problems identifie Conclusions

' Shipments of radioactive materials were made consistent with revised Department of Transportation and NRC regulation R1.2 Emeraency Response Caoability

Insoection Scooe (86750)

The inspector interviewed personnel who provide the initial response to a l transportation accident to determine whether they could provide, in a timely j manner, the emergency response information specified in 49 CFR 172.600-l 172.604.

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b. Observations and Findinas i

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The licensee's 24-hour emergency telephone number was answered by the onsite j

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fire department. The inspector interviewed personnel from the fire department that i answer this phone.' The interview included a discussion of various industry events,

! as well as, hypothetical situations. The inspector determined that these individuals were very knowledgeable regarding their emergency response role and the required response to these events.

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c. Conclusions The licensee's capability to respond to an emergency involving the transportation of radioactive materials was exceptionally goo R2 Radiological Protection and Chemistry Procedures and Documentatio Inspection Scoce (2515/133) i

, The inspector reviewed the following

• Changes made to procedures for the processing and packaging of low-specific activity material and surface contaminated objects  !

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Procedures for new leaching test requirement for Low-Specific Activity.111 l material

• Use of packaging for shipments of low-specific activity material and surface contaminated objects

• Shipping papers associated with shipments of low-specific activity material !

and surface contaminated objects l

• Use of system international units I

Procedures for the use of the radionuclide table of Ai/A2 values to assure ,

that packages do not exceed their allowable radioactivities '

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Selected A and A, values contained in the procedures to verify that the new i

values have been implemented l

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' Observations and Findinas The inspector reviewed Procedure SO123-Vil-8.2, " Shipment of Radioactive Material," Revision 13. This review included:

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• Use of international system of units

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Expansion of the radionuclide list and changes in radionuclide limits l

Transportation of low-specific activity materials and surface contaminated objects i

Classification of fissile material I

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• Preparation of shipping documents '

• Package selection l

• Labeling and placarding I i

The procedure was comprehensive and generally well presented. During this j review, the inspector noted the following-  !

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The procedure stated that Specification 7A packages were permitted for use  !

as shipping packages. According to 49 CFR 415(a), use of Specification 7A -  !

packages designed in accordance with the requirements of 49 CFR 178.350 '

in effect on June 30,1983, was not authorized after April 1,1997. The licensee conducted a review of the existing inventory of packages and determined that all packages in their possession were certified in 1989 or later.

In Attachment 9, "LSA Worksheet," the definition 'of Low-Specific Activity lli material referenced . ' CFR 173.468, which provided a leaching test requirement. There was no mechanism provided to document that the test 1 was performed and that the results were acceptable. The licensee initiated a l revision to Attachment 9 to provide a means of documenting these item l j

According to 49 CFR 172.101(c)(9), for proper shipping name, there was a ' l note indicating that if the word " waste" was not included in the hazardous  :

material description in the proper shipping name for a hazardous waste, it l shallinclude the word " Waste" preceding the proper shipping name of the material. Hazardous waste is defined as any material that is subject to the i i hazardous waste manifest requirements of 40 CFR 262. The licensee's l procedure did not address this item. The licensee stated that this w~>ld be

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j evaluated to determine if this was applicable to their shipments.

l The inspector reviewed selected A, and A2values contained in the procedures to

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verify that the new values have been implemented. These were consistent with the l current regulation I i

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.6 l Conclusions The licensee's procedure provided adequate guidance for shipment of radioactive l material I L

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R5 Staff Training and Qualification in Radiological Protection and Chemistry RS.1 Trainino and Qualification of Shinoino Personnql l Insoection Scor>e (86750)

The inspector reviewed the applicable education, experience, qualifications, and training of selected employees of the licensee responsible for processing, testing, storage, and shipping (including certification) of low-level radioactive waste and transportation of other radioactive material Observations and Findinas IE Bulletin 79-19 was issued in response to problems identified related to shipping of low level radioactive waste to disposal facilities, it provided a list of actions licensees were expected to perform, item 5 stated, in part, i

" Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in

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l your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material."

l In their response, the licensee committed to the following:

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"This training program will be expanded to include all station personnel involved in the handling, shipping, and packaging of radioactive material and will cover DOT and NRC regulatory

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requirements and instructions and procedures related to the transfer, packaging, and transport of radioactive materials."

Procedure SO123-Vil-8.2, Revision 13, " Shipment of Radioactive Material,

"Section 3.6 stated:

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"All personnel using this procedure shall be qualified in accordance with . . . IE Bulletin 79-19. . . or be directly supervised by an

, individual meeting these requirements."

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l The statement, "or be directly supervised by," appeared to be a situation where the procedure did not match the commitment. This was called to the licensee's attention. The licensee subsequently indicated their intent to review the text of the

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commitment and the procedure to determine if changes were needed to ensure consistent interpretation with current practices.

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The inspector verified that members of the radioactive materials control group, procedure writers, and procedure approving supervisors had been trained in l accordance with the licensee's commitments in the response to NRC Bulletin 7919.

Conclusions Personnel responsible for shipment of radioactivo materials were trained consistent with the licensee's commitment R5.2 Trainino and Qualification of Succort Personnel Inspection Scoce (86750)

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l The inspector interviewed personnel to determine if the licensee had provided training and periodic retraining to those employees who operate the processes that generate radioactive waste. This training should ensure that the volume of waste is minimized and is processed into acceptable chemical and physical form for transfer and shipment to a burial facilit Observations and Findinas The licensee had performed documented hazmat training for selected individual All of the radioactive material control group personnel had received this training in accordance with 49 CFR 172. However, the inspector questioned if training that satisfied the requirements of 49 CFR 172 Subpart H had been provided to individuals who supported the radioactive material control group during packaging, handling and transport of radioactive materials. Examples included carpenters, laborers, mechanics, crane operators, et The licensee provided information showing that a variety of personnel were provided hazmat training. The licensee did not have a mechanism to identify individuals who had provided support to the radioactive material control group during packaging, handling and transport of radioactive materials. As such, it was

not easily identifiable that these people had received all of the necessary hazmat

! 1 raining to perform these functions.

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8-t The process for selecting individuals to support these activities will be reviewed in a future inspection. This review will focus on the process used to verify that I these individuals have received hazmat training in accordance with 49 CFR 172 Subpart H. This was identified as an inspection followup item l l

(50-361;362/9710-01)

l Conclusions Personnel in the radioactive materials control group who performed shipping of radioactive materials were properly trained. An inspection followup item was opened which was related to the training of personnel who assist the radioactive material control group during packaging, handling, and transporting of radioactive l material R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Audits and Aonraisals I 1 Inspection Scone (86750)

The inspector reviewed results of audits performed by or for the licensee since the last inspection and evaluated the adequacy of the licensee's corrective actions. The qualifications of personnel performing audits were reviewed to ensure that audit teams included someone with experience or training commensurate with the scope, complexity, or special nature of the activities audited, Observations and Findinas The last audit of the radioactive material contrel program (including transportation)

was performed in early 1996, prior to the implementation of the new regulation There were numerous observations of the program since implementation of the new regulations. Most of these observations focused on areas that were not significantly affected by the regulation changes. The audit and the observations identified good findings. Findings were addressed in a timely manne The inspector reviewed the qualifications of selected personnel performing audits and observations of the radioactive materials control program. The individuals satisfied the licensee's qualification requirements for auditor According to ANSl/ASME N45.2.23-1978, Section 2.2, audit teams shall include someone with experience or training commensurate with the scope, complexity, or l _

special nature of the activities audited. The inspector reviewed the technical expertise of the people who performed the audit and observations. The inspector i

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i l noted that none of these individuals had expenence associated with shipping l radioactive materials. Furthermore, it had been several years since they participated in training related to transportation activities. None of the individuals had received j training related to the current regulation At the time the audit was performed in 1996, the technical expertise of the audit l team members (based upon training received) was commensurate with the existing regulations. However, since the regulatnry changes that became effective on April 1,1996, very few observations have been made regarding areas of the l program effected by the changes. As a result, the inspector pointed out that ]

portions of the program that have undergone changes were not being assessed on )

an ongoing basis.

i The licensee stated that the auditors were involved in reviewing changes to the ,

procedures and that this required them to become familiar with the changes to the i regulations. This was accomplished through desk review of the regulations and through discussions with people who would be implementing the procedur Therefore, there was no documented training to demonstrate technical expertis The inspector reviewed comments provided by the auditors during procedure change reviews. Most of the comments generated were editorial, provided j

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consistency between sections, or requested definitions / clarification of steps.

l The licensee stated that additional training would serve to improve the technical

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expertise of the quality assurance staff. The licensee stated that they would

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evaluate additional training for auditors as an opportunity for improving the quality assurance progra Conclusions The licensee assessments of the radioactive material control program were performed by personnel who were qualified according to the licensee's procedures, however documented training was not provided related to the changes to the Department of Transportation and NRC regulation R7.2 Quality Control Oversiaht of Shioments

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' Insoection Scoce (86750)

l l- The inspector reviewed selected quality assurance / quality control records of ( surveillances for shipments made since the last inspection. Training records for

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personnel performing these surveillances were reviewed.

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' Observations and Findinas During interviews with quality control personnel, the training provided associated l with inspecting the trailers used to transport radioactive materials was describe This training was provided by a retired inspector from the California Highway Patro This training was used to develop a checklist to support this' activit The individuals interviewed were very knowledgeable regarding this function. The  !

training and checklist associated with the tra;ler inspection were considered to be l exceptionally detaile ' Conclusions The training and checklist for personnel performing inspection of transport vehicles  ;

was outstandin ?

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V. l'Aanaaement Meetinas

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X1 Exit Meeting Summary l l

The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on April 25,1997. The licensee acknowledged

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the findings presented.. The licensee did not identify as proprietary any information '

or materials examined during the inspectio ,

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ATTACHMENT 1 i

, SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED 1

l Licensee E. Bennet, Nuclear Auditor i

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' D. Cox, Compliance Engineer P. Elliot, Radiation Material Control General Foreman S. Enright, Radiation Material Control Supervisor J. Madigan, Health Physics Manager S. Schofield, Health Physics Supervisor H. Wood, Nuclear Auditor J. Wood, Nuclear Training Supervisor I NRC J. Kramer, Resident inspector J. Russell, Resident inspector J. Sloan, Senior Resident inspector i

INSPECTION PROCEDURES USED l 1

IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive i Materials l Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 ITEM OPENED Ooened 361/9710-01; IFl Review process to select personnel to support 362/9710-01 transportation activities to ensure that they have had the appropriate training per 49 CFR 172 Subpart H (Section 5.2).

Document's Reviewed:

l Procedure SO123-Vll-8.1, " Solid Radioactive Waste Sampling for Classification and Typification," Revision 14 (

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Procedure SO123-Vil-8.1.2, " Radioactive Materials Curie Content Determination,"

Revision 3 l

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Procedure SO123-Vil-8.2, " Shipment of Radioactive Material," Revision 13 i

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l Audit Report SCES-611-96, " Packaging and Transportation of Radioactive Material" i

i l Letter from J. T. Head, Jr., Vice President, Southern California Edison Company to Nuclear Regulatory Commission dated September 9,1979, Response to IE Bulletin 79-19 Memorandum for File, " Dose Rate (mR/Hr) to activity (Bq/cm 2) Conversion Factors fo j surface contaminated objects Shipments," August 9,1996 Shipping Documents - Shipment 96-5609, March 7,1995 -

Shipping Documents - Shipment 96-1630, October 25,1996

Shipping Documents - Shipment 97-5704, January 30,1997 l Shipping Documents - Shipment 97-1704, February 14,1997 i

l Shipping Documents - Shipment 97-4715, April 16,1997 1^

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