IR 05000029/1981010
| ML20031G003 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/28/1981 |
| From: | Baer R, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20031F995 | List: |
| References | |
| 50-029-81-10, 50-29-81-10, NUDOCS 8110200631 | |
| Download: ML20031G003 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
81-10 Docket No.
50-29 License No.
DPR-3 Priority Category C
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Licensee:
vanican Atomic Electric ComDany i
1671 Worcester Road Framingham, Massachusetts 01701 Fccility Name:
Yankee Nuclear Power Station (Yankee Rowe)
Inspection at:
Rowe, Massachusetts Inspection conducted-June 16-19, 1981 Inspectors:
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R.'E. Baer, Ra'diation Specialist
'date' signed date signed
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date signed Approved by: ~ G wm /7 9-28-B l P. J. Knapp, Chief, Tacility 9Qldic,iogical date signed Protection Section, Technical Inspection Bronch Inspection Summary:
Inspection on June 16-I.I 1981 (Report 50-29/81-10)
n Areas Inspected: Routine, unannounced inspection by a regional based inspector of transportatic, activities including: management controls; selection of packages;
preparation of packages fer shipment; delivery of completed packages to carrier; receipt of packages; incider.< reporting; indoctrination and training program; audit program; and recordkew ag. The inspection involved 22 inspector hours on site by one regional based ir.vactor.
Results: No items of noncomp;'ance were identified.
9 110200631 010930 PDR ADOCK 05000029
,O PDR Region I Form 12 (Rev. April 77)
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D_ETAILS 1.
Persons Contacted
- Mr. H. A. Autio Plant Superintendent Mr. W. D. Billings, Chemistry and Health Physics Supervisor
- Mr. D. M. O'Donnel. Engineering Assistant, Health Physics
- Mr. D. B. Pike, Manager-0perational nuality Assurance
- Mr. L. L. Reed, Operational cuality Assurance Coordinator
- Mr. N. N. St. Laurent, Assistant Plant Superintendent
- Mr. J. C. Trejo, Health Physics Supervisor Other Personnel
- Mr. T. Foley, Resident Reactor Inspector, USNRC The inspector also interviewed several other licensee emnlo ees including health physics technicians, operations personnel and training staff mem-bers.
- denotes those persons present at the Exit Interview on June 19, 1981.
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Licensee Action on Previous inspection Findings 2.
a.
(Closed) Unresolved Item (50-29/79-15-02): Review training commit-ment - IE Bulletin 79-19. The inspector reviewed the documentation, H.P. Memorandum HP-79-71, which contained a list of personnel who received training, the type and the date the training was received.
b.
(Closed) Unresolved Item (50-29/79-15-03):
Review Procedure Number AP-2003, Attachment C, to assure that auxiliary operators are being retrained on radioactive waste procedures. The inspector reviewed Procedure Number AP-2003, Attachment C, Revision 6. Line item 27 addresses waste disposal procedures reviewed during the annual re-training.
The ir,spector also reviewed training records of eight selected operators to confirm that training had been accomplished.
3.
Management Controls The management control system for radioactive material manaqemer.t'is l
described in general in Administrative Procedure AP-8001 and more specifically in the Yankee Rowe Radiation Protection Manual. Section 5.5.2 designated the Health Physicist as the individual with the responsibility to insure the proper shipment and receipt of all radioactive material to and from the plant, Tne Plant Superintendent stated that the Healt'- Physics Supervisor as the Senior Health Physicist, was responsible for the receipt, storage i
transfer, and shipment of radioactive material.
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The Health rhysics )5upervisor had delegated the day-to-day responsibility for solid radioactive waste management to the Engineering Assistant, Health Physics. He was responsible for the collection, compaction or solidification, preparation of the sh.pment and loading of the transport vehicle. He also verified that the shipment met Nuclear Regulatory Commission (NRC), De-partment of Transportation (DOT) and burial site criteria.
There were no dedicated radioactive waste personnel.
Personnel from the operations, maintenance and health physics departments were assigned as deemed neces-sary..
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The licensee had developed and implemented procedures for the various pro-cesses and details of the radioactive material handling program.
These procedurcs included:
OP-2381, Batch Record for ~ Concentrating and Drunming Evaporator Bottoms, Revision 9.
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OP-2382, Solid Radioactive Waste Disposal, Revision 5.
OP-8300, Receiving Radioactive Material, Revision 4.
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l OP-8301, Radioactive Material Shipment, Revision 4.
OP-8302, Health Physics Release of Equipment and Material, Revision 3.
OP-8303, Preparation of Spent Ion Exchanger Resin for Shipment, Revision 0.
OP-2380, Operation of the Waste Disposal Evaporator System, Revision 6.
A documented program for indoctrination and training of personnel performing radioactive material handling was provided by the following procedures:
AP-2003, Initial and Review Qualifications o/ Auxiliary Operators, Revision 6.
AP-8001, Health Physics Departnent Organization and Training, Revision 0.
AP-9000, Qualifications and Training of Chemistry and Health Physics Per-sonnel, Revision 3.
The Operational Quality Assurance Department is responsible for planned and periodic audits of the radioactive waste management program.
The licensee had developed the following station procedures to provide guidance in implementing these audits:
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. AP-0208, In-Plant Audits, Revision 6.
0QX-X-1, Quality Assurance Inspections, Revision 3.
YOQAP-1-A, Yankee Operational Quality Assurance rogram.
Procedures establishing corporate and plant policy for the Quality As-surance Program, which incorporated the criteria of 10 CFR 71, Appendix E, included:
AP-0209, Quality Control Inspections, Revision 5.
AP-0226, Qualifications and Training of Personnel, Revision 1.
AP-0228, Quality Assurance Program, Revision 2.
Y0QAP-1-A, Yankee Operational Quality Assurance Program.
No iters of noncompliance were identified.
4.
Selection of Packages The licensee's program for selection of packages was examined against the requirements of 10 CFR 71.12 and 54 and within the framework of the DOT requirements of 49 CFR Part 173.
The inspector reviewed the licensee's records for the procurement and re-use of packages used to transport radioactive material.
The licensee had not procured or fabricated an_v packages that requirec NRC Certification.
Radioactive material shipments cequiring the use of an C Certified package (outer container) were made in vendor-supplied containers.
No containers were available during the inspection to determine conformance with the
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approval criteria, including D0T specification or Certificate marking re-quirements.
The inspector verified that the licensee had received prior approval from the NRC's Office of Nuclear Material Safety and Safeguards for all NRC
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Certified packages. The licensee had current copies of the Certificate of
.s Compliance, including the supporting safety analysis and cask handling procedures, available for all type A and B cask he was authorized to use.
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' All shipments of radioactive material were made as full load shipments in
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transport vehicles consigned for exclusive (sole) use only.
No items of noncompliance were identified.
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g 5.
Preparation of Packages for Shipment The licensee's program for preparation of radioactive material for shipment was reviewed against the requirements of 10 CFR 71.12, 31, 35, 53 and 54, and the following generally accepted codes and guides:
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Regulatory Guide 7.1 - Administrative Guide for Packaging and Trans-por ting Radioactive Material Regulatory Guide 7.4 - Ieakage Tests on Packages for Shipment of
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Radioactive Materials
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ANSI N14.10.1 - Administrative Guide for Packaging and Transporting Radioactive Materials
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ANSI N14.5 - Leakage Tests on Packages for Shipment of Radioactive Materials
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45 CFR Part 172 and 173 - Transportation The licensee had developed and implemented procedures for preparation c,f radioactive materials for shipment.
These procedures (see list in para-graph 3) included requirements for a visual inspection of the package prior to filling or loading the package; specified how to close and seal the package; marking of the package weight and contents; labeling requirements appropriate for the type of package; and radiation and contamination limits for packages.
The licensee was not packaging radioactive material during this inspection.
The-inspector noted by observation of the radioactive waste storage faci-lity and procedure review that the licensee, for shipments of low specific activity radioactive waste, used either wooden boxes as strong, tight containers or steel drums manufactured in accordance with DOT specification 17H (49 CFR 178.118).
Evaporator bottoms were solidified with concrete in the steel drums and spent demineralizer resins were dewatered in the vendor supplied steel containers.
No items of noncompliance were identified.
6.
Delivery of Cnmpleted Packages to Carrier The licensee's program for delivery of completed packages to a carrier for transport was reviewed against the requirements of 10 CFR 71.55 and 49 CFR Parts 100 to 199. Activities for delivery of completed packages to a carrier were governed by previously mentioned procedures OP-8301 and OP-8302.
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The inspector examined these procedures for consistency with regulatory requirements and to determine whether they covered all aspects of the work being performed.
Records to verify adherence to procedural requirements were also reviewed.
No items of noncompliance were identified.
7.
Receipt of Packages The licensee's program for the receipt of packages containing radioactive material was examined against the requirements of 10 CFR 20.205 and con-formance to procedure OP-8300 and the Yankee Atomic Electric Company Radia-tion Protection Manual.
The inspector reviewed these procedures for compatibility with regulatory requirements and to determine whether they covered all aspects of the work being carried out.
No items of noncompliance were identified.
8.
Incident Reporting.
The licensee uses contract carriers for the transportation of all radio-active waste packages. At each loading the carrier was supplied with a written list of personnel and agencies to contact for any incident which n ay occur during the course of transporting radioactive materials. Under instructions supplied with the list the contract carrier's dispatcher must notify the licensee of all incidents and unanticipated delays encountered during transport activity.
The licensee also used vehicles owned and operated by Yankee Atomic Electric Company for the transportation of packages containing radioactive material.
These packages were transported interstate to other power plants or to an airport.
The licensee agreed to develop and implement procedures consistent with 49 CFR 171.15 and 171.16. The inspector indicated this item will be reviewed during a subsequent inspection (50-29/81-10-01).
Packages offered for transport were inspected prior to loading on the transport vehicle and during unloading.
There have been no instances where the effectiveness of the packages were substantially reduced during use.
l Ho items of noncompliance were identifie.___-___
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Indoctrination and Training Program The licensee's indoctr. nation and training program as it pertained to the packaging of low level radioactive waste for transport and burial was examined against the provisions of IE Bulletin No. 79-19 and the licensee's response to this Bulletin.
The licensee implemented a training program and completed the initial training by January 1980.
Specific individuals received training in selected portions, according to their responsibilities, in the overall radioactive waste program.
The inspector reviewed the training records of fifteen operators and auxi-liary operators to verify they had completed the training and rttraining in accordance with Procedure AP-2003.
Training of Health Physics personnel in this area was documented by a Memorandum, HP 79-12, dated December 31, 1979.
The memorandum listed selected portions of the training program and listed the individuals com-pleting each portion.
The inspector noted that Procedure AP-9000, Qualifications and Training of Chemistry and Health Physics Personnel, Revision 3, did not address the
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training or retraining in D0T, NRC and waste burial license requirements.
Licensee representatives stated that this material would be added to the procedure. The inspector indicated that this would be reviewed during a subsequent inspection (50-29/81-10-02).
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No items of noncompliance we a identified.
10. Audit Program The licer.see's audit function for the low-level radioactive waste transfer, packaging and transport activities was examined against the requirements of 10 CFR 71 and IE Bulletin No. 79-19 and within the framework of the fol-lowing generally accepted guidance:
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Regulatory Guide 1.33 - Quality Assurance Program Requirements
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ANSI N18.7-1976 - Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants The inspector reviewed the following audits of transportation activities,
including the latest audit, conducted by the licensee:
AR-YR-80-03, dated July 29, 1980
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AR-YR-79-3-A, dated October 11, 1979 These audits were conducted in accordance with the licensee's written pro-cedures listed in paragraph 3 of this report.
Deficiencies identified during these audits were corrected prior to any more shipments being made.
No items of noncompliance were identified.
11. Recordkeeping The inspector reviewed the records of four radioactive material shipments from a total of eighty-two shipments made during calendar year 1979, and sixteen from a total of seventy-eight shipments in calendar year 1980.
The inspector also reviewed the records of all nineteen shipments made during the first quarter of calendar year 1981.
These records were reviewed for compliance with the requirements of 10 CFR 71.62.
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The licensee maintains the records of all radioactive material shipments for a period in excess of the two-year requirement.
No items of noncompliance were identified.
12.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on June 19, 1981.
The inspector sunnarized the scope and findings of the inspection.
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