IR 05000458/1989017

Insp Rept 50-458/89-17 on 890409-19.Violations Noted.Major Areas Inspected:Radiation Protection Program,Including Planning & Preparation for in-reactor Pressure Vessel Repair of Feed Water Spargers

ML20247N731
Person / Time
Site:	River Bend
Issue date:	05/16/1989
From:	Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247N706	List: IR 05000458/1989017 ML20247N704 ML20247N724
References
50-458-89-17, NUDOCS 8906060012
Download: ML20247N731 (15)

Text

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. APPENDIX B

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U.S. NUCLEAR-REGULATORY COMMISSION

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I REGION IV

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NRC Inspect 1on Report: 50-458/89-17- ' License: NPF-47 i'

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- Docketi 50-458

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Licensee: ' Gulf States Utilities (GSU)

, ..P.O.' Box 220-St. Francisville, Louisiana 70775 >'

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Facility Name: River Bend Station (RBS)'

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-Inspection'At: RBS . West Feliciana Parish

.+ St. Francisville, Louisiana

' Inspection' Conducted: April 9-19,:1989 i

' ' Inspector: * D 7 g/PF H..Chan6y) Senior RadiatierfSpecialist Dat'e Facilities Radiological Protection Section

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Approved: M e 4 cfl9 fr Baer, Chief, Facilities Radiological Date '

Protection Section Inspection Summary Inspection Conducted April 9-19, 1989 (Report 50-458/89-17)

Areas Inspectedi Routine, unannounced inspection of the licensee's radiation

- protection (RP) program, including planning and preparations for the in-reactor pressure vessel repair of the feed water sparger Results: The licensee has maintained an aggressive radiological protection progra The licensee is stili experiencing minor radiological incidents involving contamination. control practices of workers and routine radiological

- surveillance'(monitoring and-surveys). These incidents appear to be personnel related for the most part. . Management and first line ' supervisory oversight is well' implemented, but in-field critiquing of personnel is lax. ALARA planning k

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and implementation are an integral and effective part of all radiological operation The NRC inspector noted an effective coordination, planning, and conduct of the hazardous and difficult task of in-reactor vessel repair of the i feed water spargers. The licensee's preparation for radiological jobs that pose a significant radiological risk are above average. The licensee has improved performance in the area of radioactive material transport. During this inspection, three violations were identified: one for a failure to follow-procedures involving personnel qualifications (paragraph 5), and two for failure to to comply with Department of Transportation (DOT) and NRC transportation requirements (paragraph 11). Neither violation requires a response by the licensee.

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DETAILS Persons Contacted GSU

• J. Deddens, Vice President, River Bend Nuclear Group (RBNG)

• T. Plunkett, Plant Manager E. M. Cargill, Director, Radiological Programs

• T. C. Crouse, Manager of Quality Assurance (QA)

• R. G. Easlick, Raduaste Supervisor C. L. Fantacci, RP Supervisor-I. M Malik, Quality Systems Supervisor

• W H. Odell, Manager-Administration

• K. E. Suhrke, Project Management RBNG J. Davis, Senior QA Engineer R.. Wilson, Radwaste Foreman J. Cook, Licensing Engineer M. Batten, Quality Control Engineer A. Carter, Radiation Protection Technician (RPT)

R. Tunstall, RPT Foreman

• Hardy, RP Supervisor C. Spengers, Senior QA Engineer M. Vierra, ALARA Coordinator C. Edward, ALARA Technician ,

L. Vairin, Nuclear Training Representative (NTR) I G. Valentine, NTR B. Fisher, NTR D. Fauver, Dosimetry Supervisor Others E. Ford, NRC Senior Resident Inspector  !

W. Jones, NRC Resident Inspector T. Reynolds, Senior Welding Engineer, Global Divers & Contractors,  ;

Inc. (GD&C)

J. Archer, Project Manager, GD&C M. Brown, Supervisor Diver, GD&C D. Flag;, Diver, GD&C H. Hatcher, Diver, GD&C

• Denotes those present at the exit interview on April 19, 198 j The NRC inspector also interviewed several other licensee and contract employees including divers, quality assurance / quality control engineers, radwaste, and RP personne !

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' Inspector Observations AnLinspector observation is a matter discussed with the licensee during the exit. interview. Observations are neither violations, deviations, nor unresolved. items. :They-have no specific regulatory requirement, but are suggestions for the licensee's consideration, Housekeeping!- Many:arear, within the radiologically-contaminated areas were: littered with used material such as plastic. bags, plastic sheeting, and protective clothing. The general radiologicall controlled area'(RCA) of the plant was-also littered with some of-the same item Waste Minimization - Containers for general disposal of contaminated materials within the RCA and inside of contaminated areas were found-to have a'large amount of clean material in them such as paper, clear wrapping material, and cardboard packaging materials).

~ Radiological Work Practices - Field supervisors and RPTs do not 1 closely monitor work activities to identify poor radiological work practices and, when found,-they fail to aggressively critique poo radiological work practices in the field (see paragraph 9). Open Items Identified During This Inspection An open item is.a matter'that requires further review and evaluation by the NRC inspecto Open items are used to document, track, and ensure adequate followup on matters of concern to the NRC inspector. The

.following open items were identified:

Open Item Title See Paragraph 458/8917-03 Very High Radiation Area Controls 8 458/8917-04 High Plant Dose Rates 10 Followup on Previous Inspection Findings (Closed) Violation 458/8810-01: Radiation Work Permits (RWPs) - This item was previously discussed in NRC Inspection Report 50-458/88-10 and concerned the licensee's failure to review and update RWPs as required by Procedure RSP-0200. The NRC inspector examined the licensee's implementation of the corrective actions committed ~to in their July 11, 1988, response to the violation. The licensee's implementation of corrective- actions (a review of then current RWPs and a revision to

.RSP-0200 to enhance the periodic update and review process) appears to be well implemented and adequate to prevent a recurrence of the violation in the future.

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l (Closed). Violation 458/8810-02: Procedure Revisions --This . item was previously discussed in.NRC Inspection Report 50-458/88-10 and concerne the licensee's failure to ensure that when a procedure is revised, all H aspects of the' procedure (attachments / forms) are also revised to reflect; the revisions in the body of the procedur The NRC inspector examined

.the licensee's implementation of the corrective actions committed to in their July 11, 1988, response to the violation. The licensee's implementation of corrective actions (effecting a-temporary change notice E to correct the procedure involved in the violation and reinstruct

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personnel, through reading this violation and corrective actions, on the importance of ensuring all aspects of a procedure are correct following .a revision) appears to be well implemented and adequate to prevent'a recurrence of'the violation in the futur (Closed) Open Item'458/8816-01: Quality tuurance Audits - This . item was previously discussed in NRC Inspection Report 50-458/88-16 and involved'

the lack of verification of Technical Specification (TS) requirements, and Updated Safety Analysis Report (USAR) commitments when performing audit The NRC inspector examined several audits that have been accomplished by the licensee. The licensee's current audits involving RP-anc radwaste management in'cluded a review of TS and USAR items. The NRC inspector also noted that the licensee used an outside technical specialist in the RP and radwaste audits that possessed experience and technical training in the areas audited. The licensee's corrective actions appear to be sufficient to resolve the NRC's concerns in this are . Audits and Appraisals (83750)

The NRC inspector examined the licensee's quality assurance audits and surveillance program of RP and radwaste for the years 1987, 1988, and 1989. The licensee's preparations (assignment of a technical specialist, development of audit check lists, and review of past NRC, INPO, and RBS audits. findings) and conduct of audits and surveillance showed a high level of excellence. Audit findings were tracked and responses were found to be timely in most instance The following surveillance and audits were examined:

Serial N Title Surveillance 0S-87-11-08 Refueling 1, Housekeeping walk through 05-88-05-27 Review of Active RWPs 05-88-06-01 Radiation Exposure Extensions 0S-88-09-28 Personnel Radiation Exposure Records 05-88-12-08 Disposal of Contaminated Sludge (followup)

0S-88-12-09 RP Control Point Observations

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-6-p 05-89-01-35 RP Work Operations

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05-89-02-18 Records Storag RP Control Point-Observations

' Audits l 88-09-I-HPRP _

ALARA and RP Training 88-09-I-PCON/RWMP Radwaste Management / Transportation During this inspection, the NRC inspector noted that the licensee had identified a violation involving.the failure to follow a procedure

.(unqualified personnel performing RP activities) during Audit 88-09-I-HPRP. Several RPTs were found to be performing calibration and dosimetry activities that they had .not specifically qualified for as required.by RBS Procedure RSP-0003, Revision 10. The violation was well-documented and RP management's response and corrective actions were-adequate and timely. The'NRC inspector reviewed the implementation of the

licensee's corrective actions (issuance of instructions on the requirements of RSP-0003,-review of the quality of the work performed by the-unqualified personnel, andl followup surveillance of this area) and found them to be-sufficient to correct the problem and prevent a recurrence. This matter is considered to be a violation of TS 6.8.1.a. However, the licensee's actions in taking prompt remedial measures, making a full and a comprehensive evaluation and report, and the instituting of long-term corrective actions to prevent a recurrence met the criteria of the NRC enforcement policy in 10 CFR Part 2, Appendix.C (1988) for a licensee-identified ~ violation. Therefore, a Notice-of Violation will not be issued for this violatio No deviations were identifie . Changes (83750)

The NRC inspector d'iscussed with licensee representatives changes that had-been made in the licensee's facility, organization, and implementing procedures since the last inspection of this are The licensee continues to meet staffing requirements and has experienced a 25 percent turnover in Senior RPTs during 1988. Some-(less than 10 percent) of the turnover is due to internal promotions within RB Current staffing for the RPTs is 26 with an authorization of 2 Supervisory and technical support staff number 19. The licensee has recently increased the number of RPT foremen from six to seven. The procedures reviewed during this inspection are listed in the attachment to this report,

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No violations or deviations were ider.tifie s

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. Training and Qualifications (83750)-

The NRC. inspector examined the training and qualifications. aspects of the licensee'.s RP radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and methods; .

qualifications of newly hired or promoted-individuals; and provision'for appropriate RP, radwaste, and transportation training of plant personne _

Also reviewed were management techniques used to implement these programs and factoring into training industry and NRC event reports /information

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Licensee . lesson plans and tests for General Employee Training (GET) an Radiation Worker Training programs were examined and found to be adequate to ensure the requirements of 10 CFR Part 19.12 are met. Procedures and programs for the' selection and evaluation of contract RPTs were examined and found to be . satisfactory to ensure that contract RPTs were properly screened-and instructed in licensee procedures. The licensee's training programs' satisfy the commitments contained in Section 13 of the USAR and the requirements of TS 6.3.1 and 6.4 concerning RP and radwaste staff

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i training and qualification The:NRC inspector verified that RBS staff, contract RPTs, and radwaste personnel were knowledgeable of recently offered self study material on NRC and industry events (NRC Information Notices 88-79 and 89-27).

No violations or deviations were identifie . External Exposure Control (83750 and 83724)

The licensee's external radiation exposure control program was reviewed for agreement with the commitments in Section 12 of the USAR; and compliance with the requirements contained in TS 6.11, 6.10, 6.12; 10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202, 20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409; and agreement with the recommendations of NRC Inspection and Enforcement Information Notices (IEIN) 81-26, 85-42, 86-23, 86-44, 86-41, 87-39; and also the recommendations contained in NRC RGs 8.8, 8.13, 8.14, and 8.28; and industry standard ANSI N13.11-198 The NRC inspector reviewed personnel exposure records, records storage facilities, exposure control procedures, dosimetry processing procedures, dosimetry quality control methods, and data processing and report generation. Tours of stations facilities were made, and independent measurements were conducted of posted radiation areas. The licensee's high radiation area controls, including locking and control of keys, were inspected. The licensee's very high radiation area (VHRA) controls were extensively reviewed during this inspection to ensure that the licensee had implemented sufficient controls to prevent future violations of VHRA controls as described in NRC Inspection Report 50-458/88-26. The VHRA key

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-8-control program is well implemented and provides a high level of confidence that only authorized personnel have access to VHRA key Surveillance of VHRA doors is comprehensive and frequent (three times daily by either security or the RP staff).

The NRC inspector noted that the licensee had shielded high dose rate piping inside of the dry well (DW), but still established VHRA controls at the DW access hatch. The biological shield area within the DW had access doors posted as VHRAs (the NRC inspector verified dose rates in certain parts of this area to be 0.8 and 3 R/hr general area and contact dose rates of 12 to 30 R/hr). DW access controls were in the form of a nearby RPT control point that everyone had to pass through along with RPTs stationed at the roped off DW access. The licensee utilized the RPTs and briefings at the DW entrance in lieu of the flashing warning lights referenced in TS 6.1 Discussions with RP management personnel indicated they felt that the positive access controls being provided by the RPTs eliminated the need for the flashing warning lights. The RP managers had reviewed NRC IEIN 88-79, " Misuse of Flashing Lights for High Radiation Area Controls," and felt they were in a conservative postur The NRC inspector discussed with RP management the concern that without the use of red, battery powered, flashing lights, a VHRA could be left unattended or identified due to evacuation of RPTs or a partial power loss to the area (which had been occurring frequently within the DW area). The NRC inspector also discussed with the licensee that controlling the entire DW as a VHRA was inappropriate since warning devises and posting should warn personnel of hazards within their immediate area of work or passag Several areas within the DW (biological shield area and isolated areas withir the lowest level of the DW) exhibited dose rates greater than 1 R/hr. The number of areas would be too great for workers to remember during extended work operations within the DW. RP management acknowledged the need to redefine VHRA posting to specific areas within the DW and implement the use of battery operated flashing red lights to denote areas posted as VHRAs within the DW and at the accesses to the biological shield. The NRC inspector discussed these findings with Headquarters'

Nuclear Reactor Regulation personnel responsible for issuance of NRC IEIN 88-79. Since the licensee established positive access control over entries into the DW (special briefings, alarming dose rate monitors, and RPT escorts) and had areas posted a VHRAs within the DW, these findings are not being considered a violation of the requirements of TS 6.1 The NRC inspector reviewed VHRA controls for several other areas within the plant (steam tunnel and various rooms) and found them to be satisfactory. The above findings will be considered an open item pending further NRC review of the licensee's VHRA controit during future inspection (458/8917-03)

The licensee's personnel dosimetry processing program is currently (until July 31, 1989) accredited in accordance with the requirements of 10 CFR Part 20.201(c). An onsite requalification visit by a National Voluntary Laboratory Accreditation Program inspector is scheduled for June of this year. The licensee's dosimetry system had passed all eight performance categories of the industry standard ANSI N13.11 during recent offsite

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f testing. The NRC inspector observed the use of multiple dosimetry for personne1' entering areas with nonuniform radiation field The NRC inspector observed the. licensee's preparations and planning fo the! underwater repair of the feed water system spargers within the reactor -

pressure vessel;(RPV).on or about April 19,"'1989. The repair would be performed;in'the RPV while the core was fully. loaded with fuel by-underwater divers"(surface supplied air and dry suit). Very few of the licensee's RP staff had experienced this type of work previously. Th licensee accomplished the following prior to start of the underwater work:

o . Established a' planning group comprised of all contractor.(supervisor

' divers, . General Electric Engineers) and RBS organizations (planning, engineering, RP, operations, design, QA/QC, and safety) to be involved in the operatio o Held frequent meetings to evaluate progress on specific goals and reassess the schedule, o Obtained, calibrated, and function checked special underwater survey instruments. Results from these' instruments were correlated-to licensee'.s personnel dosimetry and confidence factors develope o Rp staff performed comprehensive dive site (s) dose rate mappin o The dive sites were decontaminated by high pressure water spray, o The radiological procedure (RPP-0024) for underwater diving operations was reviewed and revised utilizing the contracted diver company's procedures and procedures from another nuclear utility that performed the same job recentl o Developed an integrated radiological work and maintenance work plan that structured the performance of the work, established prerequisites, and ensured that' work operations were carefully and safely carried ou o Divers were provided general employee and radiation worker trainin Most of the 15 divers and their supervisors were experienced with RPV1 or spent fuel pool underwater wor o Work station / platform, shielding, and safety lines for the divers were designed and procured, o Mockup training (underwater.in a 40-foot deep tank) on the rerair and inspection of the spargers was conducted. RBS ALARA personnel performed time / motion studies on all aspects of the work. Special tools and work practices were also developed from the mockup trainin Motkup training was video taped and reviewed by RP management and RPTs assigned to the jo _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ - _ - _ _ _ -_--

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o Detailed briefings on the work procedures and radiological _ controls l were held and attended by all personnel associated with the jo !

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operations.

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The licensee completed this operation on or about April 26, 1989. Typical dose rates on the spargers and the RPV wall (prior to decontamination)

-combined to produce general area readings (3 feet above and below th j spargers and at a distance of 1.5 feet from the spargers) of 1.2 to '

2.5 R/hr and 1 to 6 R/hr on contact with components (spargers and RPV ';

wall). Dose rates greater than 1000 R/hr were present 5 feet below the !

' diver's work platform. The top of the active fuel in the RPV was l approximately 7 feet below the bottom of the work platform. Post I decontamination general area dose rates were found to be 0.1 to 1.5 R/h q

,The average dose rate at approximate center line of the work platform l (farthest. distance to diver, approximately 3 feet _ from RPV wall) wer 'l approximately 0.'125 to 0.2 R/hr. The primary source of radiation was from- .l the'RPV wall, spargers, and the core spray line just'below the sparger '

.Upon completion of the job, dosimetry records indicated that the divers

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received approximately 2.3 person-rem and the support crew j 0.5 person-rem, which was significantly under the ALARA staff estimate of j 4.6 person-rem for the entire job. The additional shielding added to the i work platform (bottom.and side facing the sparger/ core spray line) after decontamination dose rate surveys were performed, is partially responsible Lj for the' lower. person-rem expenditure. Extremity doses were maintained I well below.10 CFR Part 20.101 limit No violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys, and I Monitoring (83750 and 83726) )

The licensee's program for control of radioactive material (RAM),

radiological surveys, and general radiological monitoring were examined to determine compliance with the requirements of 10 CFR Part 20.20 j The NRC inspector examined approximately 75 radiation, airborne, and j contamination surveys completed by RPT technicians. The licensee had j completed surveys in accordance with the guidance of-RBS Procedures RPP-0006 and RSP-0006. Surveys were routinely performed at the

location and specified time as required by procedures. Special surveys (task related or RWP required) were frequently performed in great detail and reviewed by RPT supervisors in a timely manner. The NRC inspector noted that survey instrumentation was in current calibration and a sufficient number of each type of instrument was available. The i

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-13-licensee's instrument control and calibration program is above average in the area of. quality control and documentatio RAM controls are well implemented and the licensee. effectively utilizes high sensitivity personnel and_ equipment monitors at various exits from the RCA. Equipment is thoroughly. monitored and logged at exits to the RCA. -The NRC inspector observed personnel alarming RCA and site exi monitors. . Licensee followup was timely and effective. The licensee terminated access' authorization in one case where the individual was: found to have carelessly disregarded radiological controis within the RCA and bypassed / circumvented one set of personnel contamination monitors when

~1eaving the RC The.NRC inspector reviewed the licensee's documentation and followup on personnel contamination incidents. Ten personnel contamination incidents that were documented since the start of the refueling outage were reviewed. The licensee's documentation (RPP-0043) includes before and after decontamination results, hot particle evaluation, individual's statement of events and possible cause, RPT Foreman's assessment of the'

-incident and corrective action recommendations, trending of individual's previous incidents, and review by the RP Supervisor. One. incident

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involved the contamination (skin and clothing) of several individuals following their working in an area supposably free of contamination. This area was within the RCA of the turbine _ building. Evidently, two previou ' detailed surveys of the work area failed to detect two small areas with low levels of loose surface contamination. The previous surveys of this area involved a work survey during the breach of a system, and-a comprehensive post work radiation and contamination survey of the area to reduce radiological controls (release area). Discussions with RP managers concerning the above incident indicated that poor lighting in the area and ~

area congestion, due to piping and valves, may have contributed to the failure of the RPT to notice discoloration in the areas found contaminated (30,000 disintegrations per minute) on post incident follovup surveys. No violations were identified during the review of these incident The licensee's followup was determined to be appropriate for the circumstances depicted in the reports. Considering the hundreds of radiological surveys performed weekly by the ~1icensee, the NRC inspector determined that the l

licensee's survey program is carried out in satisfactory manner.

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' The NRC inspector observed maintenance personnel working in the main stream tunnel routinely discarding their wipe down materials on the l

floor, littering the area with contaminated material, and on the

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turbine building 95 foot elevation, there was a lack of control for used protective clothing and work material both inside and outside a contamination control area. These incidents indicated that HP technicians were not providing sufficient surveillance of work area The NRC inspector also noted that HP technicians did not aggressively pursue these issues when it was brought to their attentio No violations or deviations were identifie ;

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. The.NRC. inspector reviewed the licensee's'ALARA program (RBS Procedure-ADM-0039). The licensee's ALARA program has all the attributes of a good exposure reduction program. Workers' knowledge and work-practices demonstrated a good working knowledge of ALARA practices for radiation exposure reduction. The licensee has-a full time ALARA coordinator and staff which fluctuates according to work in progress. 'The

- licensee has a very proactive ALARA program which is evidenced by their low annual person-rem exposures. The licensee's enthusiasm and attention to detail when planning for the feed water sparger repairs was instrumental in completing the job safely and significantly below person-rem estimate The licensee's 1989 cumulative station goal of 325 person-rem may be exceeded due toothe unexpected high radiation levels being encountered throughout the dry well and reactor containment during this refueling outage . ( RF-2) . The primary contributing isotope is Cobalt 60. The licensee has not been experiencing any leaking fuel. The licensee has installed extensive temporary shielding throughout the plant. Shielding is installed following the guidance of NRC IEIN 83-64. RBS management is evaluating the significant rise in plant dose rates over that encountered in-RF-1. The licensee estimates that RF-2 alone will exceed the planned goal of 377 person-rem. Senior licensee management acknowledged th'e NRC inspector's concern over their higher than normal plant radiation level ' This area is considered an open item pending further NRC review of

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licensee findings. (458/8917-04)

l The NRC inspector also reviewed the licensee's planning for the inservice inspection (ISI) of RPV nozzles (approximately 16) from within the biological shield area, techniques to be used in ensuring these operations are conducted in an ALARA manner, and methods to be used in reducing the general area dose rates (0.8 R/hr) in proximity of the nozzles. The ISI consists of ultrasonic (automated and manual) and dye penetrant nondestructive examination'of nozzle welds. As noted in paragraph 8 of this report, the biological shield area, especially the safe-end weld areas of the nozzles, exhibited higher than usual dose rates due to crud buildup around the nozzle to pipe attachment areas and thermal sleeve The licensee tried to flush out the crud within the nozzles with system water movements to no avail. The levels actually increase in some nozzle A remotely operated (refueling floor area) high pressure water lance was used to wash down "hydrolazing" the interior of the nozzle This decontamination was successful in reducing the general area dose rates at some nozzles from approximately 0.8 R/hr to 0.240 R/hr. Contact dose rates were reduced from 12 R/hr to 1.2 R/hr. Due to the cramped work space in the biological shield area (approximately a 3-foot clearance between the RPV and the biological shield wall) and the congestion due to the nozzles, wholesale shielding of nozzles was not considered beneficial, and would only put the person-rem expenditure on another group of workers (shielding installers). However, discriminate shielding packages were used where possible to reduce dose rates on one side of large nozzles during some inspections. Nozzle decontamination, worker briefings, and l

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mockup training resulted in'ISIl inspectors being able to process 2 to-

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3 nozzles-by' manual inspection'during each trip into the biological: shield-area. Further high pressure decontamination of other nozzles is planned after completion. of the feed water sparger repair wor 'The NRC inspector-reviewed five work operations and the associated RWP Three of_the RWPsl involved the entry _of personnel into VHRAs. Licensee control of exposures and management of-personnel dose extensions was well documented-. RWP reviews by the-ALARA staff. appeared'to be effective. The licensee extensively utilized filtered (particulate and iodines) exhaust ventilation systems to reduce the need'for respiratory ' protection equipmen No violations or deviations were identifie . Shipping'of Low-Level Waste for Disposal, and Transportation (83750)

The NRC inspector reviewed the licensee's program for the control, classification, characterization, and . shipment 'of low level radioactive waste;to determine compliance with the requirements of 10 CFR Parts 20.305, 20.311, and 71.0; 49 CFR Parts 171 through 178; commitments contained in Section 11 of the USAR; recommendations of NRCl Branch Technical Position papers on low level radioactive waste classification and waste form; and IEIN 89-27. The licensee program for the transportation of RAM waste also reviewe The licensee's. program for collection,, processing, characterization and classification of wastes and. inspection and closure of shipping casks were examined and found to be well documented. The NRC inspector noted that the licensee relies on detailed checklists with sign-offs for all ,

. regulated activities involving RAM and waste processing. The licensee is i currently utilizing a lease processing system for the solidification of liquids and resins that is on the NRC approved . topical report lists of

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radwaste volume reduction processes.

i -The NRC inspector reviewed the licensee's response to a Notice of

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. Violation issued by the state of South Carolina involving a shipment of radioactive waste to Chem-Nuclear Systems (CNS), Inc. burial facility in Barnwell, South Carolina. The shipment was low specific activity (LSA)

resins solidified-in cement, packaged in a steel liner, and transported as Exclusive Use in a CNS 14-215-H-1 shipping' cask, Shipment 0788-019, on July 12, 1988. The-violations involved:

o Misidentification of gross amount of radioactivity in the shipmen Listed as being 13.8 millicurie (mC1) versus an actual quantity of 59,015 mc (49 CFR Parts 172.203 and 172.204)

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-o Shipment was classified.as A" unstable instead of the required designation.of "A" stable (CNS burial permit requirements). NRC requirements (10 CFR 61) require o'nly A, B, or C designators.

o Shipment manifest listed no chelating agents when the shipment actually contained approximately 4.1 percent by volume of chelating agents. (10 CFR Part 20.311)

o The radiological analysis' accompanying the shipment did not accurately reflect the radionuclides identification and concentrations.in the shipmen (10 CFR Part 20.311).

On July 15, 1989,- CNS verified that the shipment manifest did not agree with.the radiological conditions found during off loading of the line The state.of South Carolina assessed RBS a two thousand five hundred dollar ($2,500) fine and suspended use of the CNS facility-by RBS until corrective actions had been taken and' acknowledged by the state of South Carolin The NRC inspector examined'the licensee's documentation.of the events surrounding this incident and the licensee's corrective actions to prevent a future recurrence of the violations. The licensee identified personnel and procedural errors, and deficiencies in the computerized program used for processing of shipment manifests as the cause of the violations. The licensee's root cause analysis was accurate and corrective sctions (Radwaste Procedures RWS-0327, " Shipping of LSA, Radioactive Material" and

"RWS-0207, "Radwaste Shipping Criteria," were revised to provide a high degree of quality control over shipments and processing of documents) were adequate to prevent a recurrence of the violations. The licensee's corrective actions were accepted by the state of South Carolina and acknowledged via letter to the licensee on August 23, 198 No deviations were identifie . Exit Interview The NRC inspector met with licensee representatives identified in paragraph I at the-conclusion of the inspection on April 19, 198 The NRC inspector summarized the scope and findings of the inspectio _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ __ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ -

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. ATTACHMENT L 'TO NRC INSPECTION REPORT 50-458/89-17 ,

I DOCUMENTS REVIEWED TITLE REVISION DATE Station Operating Manual

' Administrative Procedures (ADM)

ADM-0025, Conduct of Radiation Protection Services 4 03/28/89 ADM-0038, Radioactive Waste Management Program 4 08/26/87 ADM-0039, ALARA Program . 2 07/07/87-RBNP-50, Radwaste Minimization Program 0 02/14/89 Radiation Section Procedures (RSP)

RSP-0003, Personnel Qualification for the Radiation Protection Section 10 07/29/88 RSP-0006, Radiation Protection Task Scheduling 4 09/13/88 RSP-0009, ALARA Program Implementation 3 02/01/89 RSP-0200, Radiation Work Permits 5 03/13/89 RSP-0201, Respiratory Protection for Radiological Areas 2 08/03/87 RSP-0212, Dry Well Entry 3 08/19/87 RSP-0213 Control and. Handling of Radioactive Material 5 07/08/88 RSP-0214, Control of Radiation Protection Group Software 0 07/29/88 Radiation Protection Procedures (RPP)

RPP-0005, Posting of Radiologically Controlled Areas 6 02/17/89 RPP-0006, Radiological Surveys 3 09/01/87 RPP-0010, Operation and Verification of the Shepard Model 89 Gamma Calibrator 3 01/04/89 RPP-0013, Survey Instrument Response Tests 4 06/15/88 RPP-0024, Radiological Precautions for Underwater Diving Operations 2 04/18/89 RPP-0025, Radiography Requirements 1 07/10/87 RPP-0059, Portable HEPA Filtration 4 03/28/89

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