IR 05000206/1981011
| ML19345H444 | |
| Person / Time | |
|---|---|
| Site: | San Onofre |
| Issue date: | 04/21/1981 |
| From: | Book H, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345H443 | List: |
| References | |
| 50-206-81-11, NUDOCS 8105200307 | |
| Download: ML19345H444 (13) | |
Text
...
_
_ _
_
l
.
O-U. S. NUCLEAR REGUIATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
50-206/81-11 Docket No.
50-206 License No.
DPR-13 Safeguards Group I.icensee:
Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Unit 1 (SONG-1)
Inspection at:
Camp Pendleton, California Inspection conducted:
March 30 - April 3,1981 Inspectors: b he dVA N.2 / - % I G. P. {uths, Radiation Specialist Date Signed
\\j Date Signed
}*
, ff4 Y/
l Approved by:
F.
. Wensl ski / Chief, Reactor Radiation Protection Wate' Signed g
Section f
N/
0-Approved By:
m
.
i H.
E'. Book, Chief, Radiological Safety Branch Date' Signed
'l Summary:
Inspection on March 30 - April 3,1981 - Report No. 50-206/81-11 Areas Inspected:
Routine unannounced inspection by a regional based inspector of transportation activities as they pertain to the processes of receipt, i
packaging, transfer, delivery to a carrier, and transport of radioactive materials including periodic maintenance of packaging and followup of previously i
.
l identified radiation protection activities. The inspection involved 38 inspector-hours onsite.
Results: Of the areas inspected, no items of noncompliance were identified.
i i
I 8105200'307 RV Form 219 (2)
.
_. -
- -.
-
_ - _ _ -. _ _
- - -. _. - _. _ - _ _. -
-, _ _..
. - -.
_ _ _, - - - _ -. - _ -
.
.
DETAILS 1.
Persons Contacted Southern California Edison Company
.
- J. G. Haynes, Manager, Nuclear Operaticns
- D. E. Nunn, Manager, Quality Assurance
- J. M. Curran, Plant Manager, San Onofre
- R. V. Warnock, Radiation Protection Supervisor
- G. W. Mcdonald, Quality Assurance / Quality Control Supervisor
- J. D. Dunn, Project Quality Assurance Supervisor
- D. D. Duran, Engineer Responsible for Transportation of Radioactive Material
- E. J. Bennett, Radiation Protection Foreman
- R. Morgan, Radioactive Waste Foreman R. Brown, Quality A.;surance Engineer
- H. Key, Quality Assurance Engineer
- f. Briggs, Compliance Engineer J. Mortensen, Health Physics Engineer Non Licensee Representatives
- B. Allen, Consultant
- F. Lesko, Proto-Power Manage: tent Corpration
,
J. Massey, Applied Techonolgy of Barnwell Inc.
- Denotes those individuals attending the exit interview.
In addition to the individuals noted above the inspector met with and interviewed numerous other members of the licensee's and contractor's
staffs.
l 2.
Licensee Action on Previously Identified Radiation Protection Related Matters.
(Closed) IE Bulletin 80-10, " Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release of l
Radioactivity to Environment". The licensee's response to this l
bulletin was reviewed and documented in Inspection Report No. 50-206/80-33.
l In a letter te 'he Director, USNRC Region V dated March 31, 1981 the licensee statea that the oily waste sump and yard drain sump have been identified as potential pathways for release and that radiation monitors will be installed. During the tour of controlled areas on March 30, 1981 the inspector observed that the 500 gallon sanitary collection sump which fills from the steam generator personnel entry point was over flowing to the yard drain system. The volume of waste flow to this i
sump requires that it be pumped down several times a day. The sump is pumped by a contractor and disposed of off site.
The licensee's
!
evaluation of this sump concluded that the posibility of it becoming contaminated was so small that no sampling regime was indicated. The
'
j inspector concurred that the potential for contamination is small but discussed with licensee representatives the prudence of periodic l
l sampling of this material since it is leaving the restricted area.
l l
__
,,
. _ _
_
-
.
__
_ _ _. __
_ _.
_-
- _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.. - _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ -. _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _
-2-
.
(Closed) Paragraph 5 of Inspection Report fla. 50-206/81-02 describes radiation levels up to 0.1 mr/hr on the beach in front of the Tsunami wall. These levels, for the most part appeared to be due to the accumulation of radioactive material stored in the concrete block cubicle located adjacent to the Auxiliary Building. During the March 30, 1981 tour the inspector observed that the licensee has disposed of much of the radioactive materM ;tored in the cubicle and relocated other material to three concrete shielded vaults placed in the same area. The inspector performed a radiation survey of the area using an Eberline Model R0-2, Serial flo. 9364, oortable ionization chamber, due for calibration on April 30, 1981. The radiation level at the entrance to the cubicle decreased from 420 mr/hr at the last inspection to less than 1 mr/hr, and from 550 mr/hr on the roof to less than 1 mr/hr at this inspection. The maximum contact dose measured on the shielded vault was 40 mr/hr.
Review of the licensee's survey of the beach performed on March 8, 1981 with a portable low level radiation survey instrument indicated a maximum dose rate of 0.05 mr/hr and an average dose rate of 0.02 mr/hr. The licensee'.s actions regarding this matter are consistant with the ALARA criterion.
In addition, the licensee has solicited two independent reviews of the radioactive waste treatment and handling systems. A draft report titled, " Modifications to the Solid Radioactive Waste Disposal System" prepared by Apolied Techonolgy of Barnwell Inc. was reviewed and discussed with licensee and contractor representatives.
The second report being prepared by NUS Corporation is scheduled for completion in August 1981.
(Closed) 10 CFR 50.72, "flotification of significant events". On February 17,1981 at 8:10 PM the licensee informed the flRC Operations Center that an individual wearing respiratory protection while working on the "B" steam generator.platfonn passed out and was taken to a local hospital. Similiar instances occurred on February 9 and Februay 13, 1981.
In all cases the individuals were not cor.taminated with radioactive materials when transported offsite.
The diagnosis offered to the licensee was that the individuals were suffering from heat prostration and dehydration. The licensee notified California-0SHA.
California-0SHA visited the site on February 20, 1981.
Since the individuals involved in these incidents were wearing air supplied hoods the inspector reviewed samples of supplied air collected
'
by the licensee to verify compliance with the air quality requirements referenced in Regulatory Guide 8.15 " Acceptable Programs for Respiratory Protection".
Since February 1,1981 nine samples were analyzed by the licensee and five samples by an independent laboratory. - All samples met De Grade D air quality requirement specified thru 10 CFR 20.103. The lice see concluded that excessive protective clothing and poor physical conditioning combined with the sometime arduous nature of the tasks were responsible for these events. To minimize the potential of additional problems the licensee deleted the paper inner coveralls from the protective clothing requirements, limited each worker to a maximum of of two hours when on the platforms and instructed all workers to immediately inform the Radiation Protection Technician if they begin to feel weak or 111.
t
^ " - *
"
F w
e
,c
,, _,_
-3-
.
(Closed) On February 19, 1981 the licensee notified NRC Region V by telephone that c small quantity of radioactive material had been inadvertenly released from the restricted area. The inspector reviewed the circumstances surrounding this release to determine if regubtory requirements had been violated.
From record review and discussion with licensee representatives it appears that on December 1,1980 while conducting a dewatering test on 70 cubic feet of new resin a hose contaminated with radioactive material was used to fill the container with water. The container was allowed to soak for one hour and was then dewatered and blown dry with nitrogen.
After several additional wait periods the drain plug on the bottom of the strong-tight container was opened and no water was observed.
The test completed, the container of resin was given to Southwest Nuclear (California License No. 2873-60). On February'12, 1981 Southwest Nuclear' notified the licensee that the resin appeared to be contaminated based on a direct radiation reading of 0.5 mr/hr on the surface of the liner. The licensee analyzed a sample of the resin which they had retained and found the following:
Isotope Specific Activity uCi/ gram 134 Cs 3.43 E-6 137 Cs 4.55 E-6 60 Co 1.62 E-6 Based on these results the licensec calculated the total activity involved to be:
Isotope Total Activity uCi 134 Cs 5.7 i
137 Cs 7.64 60 Co 2.73 On March 3,1981 the licensee representative directed the repackaging and shipment of the low level contaminated resins to an authorized disposal facility.
Since the total specific activity is less than that requiring packaging, marking or. labeling by 49 CFR 173.389 and since the material was fortuitous transferred to a licensed individual as required by 10 CFR 30.41, no item of noncompliance is identified.
However, the control of contaminated material was again emphasized to the licensee representatives.
l
!
i
{ ^
(Closed) Transient worker contact. On March 25, 1981 a transient worker who had been assigned to the steam generator repair activity telephoned NRC Region V to find out if he was required to be whole body counted on termination of his work assignment.
In the telephone discussion with the inspector other points involving questionable radiation protection practices were made. The individual was informed of the provisions of 10 CFR 19.16 " Request by workers for inspections," but stated that he neither was requesting an inspection nor making an allegation. The individual agreed to allow NRC to use his name in bringing these matters to the licensee's attention.
On March 25, 1981 the inspector contacted the licensee Health Physics Engineer and informed him of the following points made by the individual:
1.
He did not receive a whole body count.on termination of work assignment.
2.
He thcught that he may have received a dose of 300 mrem while waiting on the Turbine Deck on March 14, 1981.
3.
At one point while working inside a steam generator, he slipped, tore his plastic suit and cut his leg. The Radiation Protection Technician did not survey his cut.
4.
He heard that sleeves were being improperly ' installed and that plugs were being placed in the wrong steam generator tubes.
During this inspection dosimetry records were reviewed and discussion held with licensee representatives to followup on each point noted above. According to the individual's employer, the man was fired on March 24, 1981 for arriving at work in an unacceptable condition.
He was told to get a whole body count in accordance with procedure SPRP-008, " Health Physics Program for the Steam Generator Repair Project".
He refused to be whole body counted at that time...He was contacted by the licensee and scheduled for a whole body count on April 6, 1981. The individual failed to show up for the whole count.
The licensee will schedule another count.
Review of dosimetry, rec,rds including self' reading pocket dosimeters, film badge and thercoluminescent dosimeter results did not indicate an unanticipated
~
dose associated with the Turbine Deck. The records did indicate tnat this individual had apparently worn the dosimetry packat of another individual with a very similiar name on March 22,198.
The inspector verified that the final dose recorded for each individual,as correct and that the licensee had reinstructed dosimetry terminal operators to verify that each individual is wearing the proper dosimetry packet. Although the individual stated that he had informed a Radiation Protection Technician of the minor cut on his leg no record was found to indicate that a official survey by a Radiation Protection Technician was made. Neither the individual nor the licensee was able to identify which technician was told. The individual stated that he had surveyed the cut and found it to be free of contamination and that he did not report it to First Aid as he had been instructed.
Rumors regarding improperly installed sleeves and plugs have been substantiated by the licensee and corrective actions initiated via the quality control process.
No items of noncompliance were identifie _ _ _ _ _ _ _ _ _
-5-
.
.
(Closed) Transient worker contact, on March 28, 1981 a transient worker informed the NRC Operations Center that he believed he may have received a radiation exposure in excess of the regulatory limit while working on the sf.eam generator repair activity.
The inspector contacted this individual on March 30, 1981. The individual stated that based on what a co-worker had gleaned from the dosimetry computer he felt that he may have received a dose of 3.4 rem during his assignment at SONGS 1.
He stated that he had been fired by his employer on March 28, 1981 as a result of an altercation with his assigned Security Escort. He stated the " security is a joke" but did not offer specifics to substantiate his comment. He did not want to request an inspection or make an.allgation but only wanted to know how accurate his exposure records.were. He stated that he would contact the licensee and request an explanatidn of his exposure history. The inspector reviewed this individuals exposure data sheets and film badge results and found agreement between his self reading pocket dosimeter, filr badge, and thermoluminescent results. The cumulative exposure for his visit to SONGS 1 was 1.97 rem. On April 1, 1981 between 7 PM and 10:30 PM the inspector made an unannounced tour of the controlled areas including the containment and steam generator repair activity. The purpose of the tour was to make independent radiation measurements, observe radiation control practices and procedures, and to observe the security escort procedure as implemented for the steam generator repair acitivity. At approximately 7:40 PM the inspector demonstrated to the Soutern California Edison Company, Shift Supervising Officer that the contract officer assigned to Post 53 to insure that individuals entering the controlled area were wearing the reouired dosimetry packet was not perfoming his intended function.
The Shift Supervising Officer in his report stated that the contract officer was asleep. The inspector verified thru the Supervisor of Plant Security that Post 53 is not required by tre Security Plan but is an additional measure taken to insure that workers are properly cadged when entering the controlled area.
Dosimetry control practices, Security Escort precedures and radiation control measures appeared adequate and consiste.nt with procedural controls during the remainer of the tour.
On April 3,1980 the inspector contacted the individual and explained the results of the dosimetry review and tour of the work area. The individual stated agreement with the dosimeter records and concluded that his cumulative exposure was within regulatory limits.
The individual stated that he was satisfied that his exposure concern had been addressed and that he had no specific concerns in the security area.
No items of noncompliance were identified in review of this matter.
(Closed) Exposure in Excess of 10 CFR 20.101(a), NRC Region II notified Region V on March 18, 1981 that a transient worker engaged in steam generator repair activities at the H. B. Robinson facility during the second calender quarter of 1980 actually received 123 mrem more than he had been informed of pursuant to 10 CFR 19.13(e). The individual had also worked at SONGS I during the remainder of the second calender quarter of 1980 and was again involved in steam generator repair activities. On arrival at SONGS 1 the individual provided a written
-6-
.
estimate of his current quarterly exposure on SCE Form 242 pursuant to 10 CFR 20.102(a) indicating that he had received 1146 mrem in the period April 14-28, 1980.
During the remainder of the quarter the licensee permitted this individual to accumulate a calculateri additional 1781 mrem for a total second quarter exposure of 2927 mrem.
In a letter dated March 25, 1981, Carolina Power and Light Company operator of H. B. Robinson informed the licensee of the additional 123 mrem. The inspector met with the licensee Dosimetry Supervisor on April 3,1981 and was informed that a 10 CFR 20.405 report will be submitted for this querterly exposure of 3.05 rem.
6,1979 (44 FR 32349) published in the Federal In view of the Statesents of Consideration no enforcement acticn will Register flotice June be taken against Southern California Edison Company since they limited the individuals exposure based on the best information available to them at the time of his work assignment.
3.
Transportation Activities
a.
Management Controls San Onofre fluclear Generating Station, Station Order S-E-205,
" Receipt and Shipment of Radioactive Material", Revision 3, December 19, 1979 defines personnel responsibilities and establishes the procedures for receiving and shipping radioactive materials including nuclear fuel. This procedure states that:
"The Chemical-Radiation Protection Engineer is responsible for the safe transfer, packaging and transport of radioactive material."
In the September 30, 1980 response to the Health Physics Appraisal findings the licensee stated that a radiation protection engineer, radiation protection foreman, and cadre of technicians and helpers have been assigned full time to the radioactive waste management area. Based on discussions with these individuals their responsibilities have been delineated in Health Physics Procedure S01-VII-8.0, " Solid Waste Program",
Revision 0, January 30, 1981. On February 2,1981 the licensee l
submitted Amendment 96 consisting of Proposed Change fio.101 to the Technical Specifications which would establish the position
of Radwaste Supervisor reporting to the Health Physics Manager.
The licensee representative stated that with issuance of
Amendment 96, S-E-205 and other station orders (501-E-211) will i
be revised to more clearly describe the duties and responsibilities of members of the health physics organization.
l The licensee has been actively involved in revision and development of the radioactive material packaging and shipping program. The licensee has contracted with Allied Techonology of Barnwell Inc.
and IlUS Corporation to support this program development. The inspector reviewed the procedures listed below to determine if thcy have been developed consistent with the requirements of Technical Specification 6.8,10 CFR 30,10 CFR 71, 49 CFR 100-199 and the burial site criteria.
.
.
~
-7-
.
.
F Procedure No.
Title Revision No.
S-E-205 Receipt and Shipment of Radioactive Material-3 S01-V II-8.0 Solid Waste Program
S01-VII-8.1.1 Solid Waste Records and Reports
S01 -V II-8. 2.1 Shipment of Spent Fuel
S01-5-6 Transferring Resins from the Spent Resin Storage Tank to the Shipping Cask
S-VII-1.7 Spent Resin Shipment
S-XII-1.32 Spent Resin Shipping Container Inspection
S-VII-1.20 Solid Radioactive Waste Shipments
S01-VII-1. 26 Radiatit:n Protection for Spent Fuel Shipments
501-VII-1.41 Receiving Radioactive Materials
501-VII-1. 56 Compacting Low Level Radioactive Waste
SPM-38 Procedure for Solid Waste Loading of CNS8-120 Shipping Cask
~
Procedure No.
Title Revision No.
SPM-39 Procedure for loading iligh Radwaste Liner Into CNS8-120 Shipping Cask
SPM-40 Procedure for Solid !!aste Loading of CNS 14-195-H Shipping Cask
l SPM-41 Procedure for Transferring Resins from the Southwest Nuclear Resin Liners to the Shipping Cask
j SPM-42 Procedure for Filling Resin Liner in CNS 195-H Cask
i Recognizing that the procedures are currently undergoing revision the following inspector observations are noted:
1.
Several procedures have been issued which reference S01-VII-8.1,
" Solid Radioactive Waste Packaging, Labeling and Shipments,"
and S01-VII-8.2. " Shipment of an Receipt of Radioactive Material"
,
!
which have nc' een issued.
2.
The procedures do not clearly include the requirements expressed in 10 CFR 30.41, " Transfer of byproduct material".
.
-8-
.
.
3.
Listed references for S-VII-1.20 does not include the State of Washington burial criteria.
4.
The dose rate limit at 2 meters specified,in 501-VII-1.27 and S-VII-1.7 are inconsistant with the values specified in
S-VII-1.20/G PCN4.
5.
Procedure S01-VII-8.1.1 does not reference all the requirements expressed in 10 CFR 71.62 and S-E-205.
6.
The procedures do not address transport of radioactive material in licensee owned vehicles.
Station Order S-A-126, " Personnel Training", Revision 7 describes a training program to be completed by those individuals involved in the packaging and shipment of radioactive waste. The procedure also states that annual retraining sessions will be provided.
I The inspector verified that the Radiation Protection Engineer had onsite up-to-date copies of Chapters 10 and 49 Parts 100-199 of the Code of Federal Regulations and a current copy of the State of Washington License No. WN-1019-2.
Revision 6 of the licensce's Quality Assurance Plan incorporated the criteria of 10 CFR 71, Appendix E.
Procedure QAPN-18-04 requires the annual <fevelopment of an audit schedule. This audit schedule typically includes an audit of some aspect of the packaging and shipment of radioactive material.s area.
'
No items of noncompliance were identified in this area.
b.
Implementation During the first calander quarter of 1981 the licensee delivered to a carrier for transport 1,348, 55 gallon drums, 19 boxes, and 8 liners totaling 12,180 cubic feet. These shipments contained a total of 63.9 curies of mixed fission and activitation products. This material met the low specific activity (LSA) criteria specified in 10 CFR 71.4(g). The packaging used consisted of
new 17H drums, B-25 boxes and Southwest Nuclear Company single use, strong, tight containers as permitted by 49 CFR 173.392.
Six shipments of depleted resin containing 280 curies meeting the LSA criterion were placed in NRC certified packages and shipped during the first calende' quarter of 1981.
The inspector verified that the licensee had onsite a copy of the current NRC Certificate of Compliance for Model Nos. CNSI-14-195H, LL50-100 and B2 packages.- In addition to this documentation the inspector verified that the licensee registered as a user of each package as required by 10 CFR 71.12 and had a copy of all documents and drawings referred to in the certificate.
The licensee maintains a loose leaf binder supplied by the package owner for each package noted above. This binder also contains detailed operating instructions for each package and additional guidance.
__
.
.g.
.
O Condition No. 27f of burial License WN 1019-2 requires that dewatered ion exchange. resins have no detectable free-standing liquid. This is defined as less than 0.5% or one gallon per container, whichever is less. The licensee uses a liner (Drawing No. GlP226) to contain the resins placed in the certified containers. The insnector reviewed the results of a test conducted in November and December 1980 to demonstrate compliance with this criteria.
Inspection Planning Data Report No. CIP-239 was reviewed and indicates the test was preformed in accordance with a written procedure and observed by a Quality Control Department inspector. The test provides reasonable assurance that the free-standing liquid criteria will be met when the resin liner has been dewatered in accordance with S01-5-6.
Due to litigation between the State of Illinos, General Electric Company and the licensee, shipment of spent nuclear fuel has been suspended. Therefore, no effort was made to review the licensee program for transfer of spent nuclear fuel during this inspection.
No items of noncompliance were identified in this area.
c.
Preparation of Packages for Shipment The inspector verified by record view that the licensee has written procedures to insure that certified packages are inspected
,
as required prior to each use.
Inspection Planning Data Reports (IPDR) for three shipments were reviewed. These are noted below:
,
Licensee
'
Identification No.
Date Package IPDR
!
l SW-10 February 5, 1981 LL50-100 RIP-P-27 l
l SW-14 February 21, 1981 B2 HIP ~P-41 R-1 January 26, 1981 LL50-100 RIP-R-10 The licensee contracts for the certified containers' used and i
l routinely does not perform periodic maintenance exce.ot for those items required for closure, such as gaskets. The Quality Assurance Engineer had on file letters from the containers' owners which indicated the gaskets had been replaced within the specified frequency.
When performing receipt inspection RIP-P-41 on February 19, 1981 the licensca discovered that 1 of 46 holdown bolt retention nuts had broken. The inspector discussed this repair activity with the responsible individuals and reviewed repair records and drawings.
Prior to the repair, the container owner, U.S. Ecology, was contacted and authorized the work. The repair was conducted in accordance with SCE Welding Record S01-81-034 which referenced the Kenasco Corporation Drawing. Documentation indicates that the materials
,
and work were performed consistant with Drawing No. 6901-002B j
specifications.
U.S. Ecology's Chief Radiological Control and i
Safety Officer visited the licensee on March 18, 1981 to review the licensee's quality assurance program in general and to specifically review this repair activity.
l i
.m.
.
,
-_-
- -. - -
-
,
.-.
-10-
.
.
The inspector reviewed records of the following shipments of radioactive material to determine if they had been loaded and closed in accordance with written procedures.
i License Identification No.
Date
. package SW-10 February 5, 1981 LL50-100 SW-14 February 21, 1981 B2
'
R-1 January 26, 1981 LL50-100 R-2 February 18, 1981 LL50-100 R-3 February 26, 1981 LL50-100 R-4 March 9, 1981 LL50-100 R-6 March 23, 1981 LL50-100
'
In all instances records (PSS0-419) indicate the containers were loaded and closed in accordance with the certificates of compliance as required by 10 CFR 71.54.
In addition to the shipments referenced above the following special shipments were reviewed to determine compliance with package marking, labeling and radiation limit requirements expressed in 10 CFR 71.5 and 49 CFR l'/2 :nd 173.
l Licensee
~
'
Identification No.
Date Package S-1 January 21, 1981 LSA
,
S-2 February 20, 1981 LSA S-3 February 24, 1981 LSA All of the reviewed shipments were classified as LSA by the licensee. The inspector reviewed sample results and perfonned independent calculations of the specific activity.
In the case of SW-14 the licensee included the mass of absorbent material in a 17H drum surrounding the radioactive fiber filters.
Using only the mass of the filters the shipment still met the LSA criteria.
The requirements of 10 CFR 71.4(g) regarding LSA were reviewed with the licensee.
No item of noncompliance was identified in this area.
d.
Delivery of Completed Packages to Carricrs For the shipments referenced above the inspector reviewed the following licensee, broker, and carrier documents to determine compliance with 10 CFR 71.5, 49 CFR 172 and 173 and 10 CFR 30.41.
L
. _ _. _ _
.
..
_ _ _ _ _
-11-
.
.
Radioactive Shipment Check off Sheet
-
Radioactive Material Shipping Record
-
Radioactive Waste Shipment and Disposal Form
-
Straight Bill of Lading
-
Instruction to Carrier for l'aintenance of Exclusive Use
-
of Shipment Controlls
-
Washington State Certification On April 2,1981 the inspector observed the licensee delivering a shipment (SW-25) of low level LSA drums ar,d boxes in a closed van to a carrier for transport. Using an NRC Eberline R02 Serial No. 9864 the inspection performed independent measurements of the radiation levels at contact, two meters and inside the tractor cab. The trailer was locked and properly placarded. The shipping papers were in order and the licensee's dose rate measurements were consistant with NRC values of 12 mr/hr at contact, 0.8 mr/hr at 2 meters, and 0.2 mr/hr in the tractor. The tractor, Nevada license 56031A, was observed to have a large spider crack in the right half side of the split windshield. The driver stated that the crack occurred a few days ago and that he was permitted to continue using the tractor for several more days. The inspector confirmed this to be acceptable with a representative of the Department of Transportation.
Review of the shipping records indicates compliance with the requirements expressed in 10 CFR 71.62 and 49 CFR 172.200. A few anomalies were observed:
-
The Radiation Shipment Record No. was omitted from the Washington State Certification for shipments SW-10 and R-1.
The radioactive Shipment Check-off Sheet was incomplete for
-
shipments SW-14 and R-1.
The shipper's certificrtion on the Straight Bill of Lading
-
for S-2 was not signed. The licensee representative stated that the Radioactive Material Shipment Record which contained a signed certification was provided to the carrier.
The receiver's license number was incorrect on the Radioactive
-
Material Shipment Record for shipment S-3.
For receivers other then WN-1019-2, the licensee had considerable difficulty demonstrating that they were aware of the receivers authori-zation to accept the material being shippe m-12-
.
.
These. points plus the fact that the shioping papers are not being signed by the Chemical-Radiation Protection Engineer prior to filing as called for in S-E-205 were brought to the licensee's attention. The licensee representative stated that the procedure and the Radioactive Shipment Check-off Sheet will be revised to include a verification signature that all the shipping forms have been properly completed.
No items of noncompliance were identified in this area.
d.
Radwaste Training The inspector reviewed the licensee's " Training Manual for-Radioactive Waste Packaging and Shipping", dated January 1980.
This manual constitutes the course outline provided pursuant to Section XIV of Station Order S-A-126, " Personnel Training".
The course is geared to the needs of the cadre of technicians involved in transportation activities. The inspector verified by record review that each of the six technicians involved in transportation activities had received this training during 1981.
No items of noncompliance were identified in this area.
e.
Licensee Audits The inspector reviewed Audit Report No. 501-17-81. This audit of the 1980 radioactive waste disposal records was performed in the period January 15 through March 6,1981.
The audit was performed in accordance with an inspection plan by two individuals experienced in transportation activities.
No corrective action reports were generated as a result of the audit.
The inspector made an independent accounting of the volume and activity of radioactive material shipped during 1980 based on individual shipment records that confirmed the veracity of the licensee's Semi-Annual Effluent Release Reports for 1980.
No items of noncompliance were identified in this area.
4.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conc?usion of the inspection on April 3,1981.
l The inspector summarized the scope and findings of the inspection.
L
!
.
,
,
.-
-
-
,-
,
w