IR 05000213/1979019

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IE Insp Rept 50-213/79-19 on 791107-08.Noncompliance Noted: All Documents Referenced by Certificate of Compliance Not Available
ML19294B429
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 12/21/1979
From: Clemons P, Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19294B410 List:
References
50-213-79-19, NUDOCS 8002280351
Download: ML19294B429 (6)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.

50-213/79-19 Docket No.

50-213 License No.

DPR-61 Priority

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Category C

Licensee:

Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name:

Haddam Neck Inspection at:

Haddam Neck, Connecticut Inspection conducted:

November 7-8, 1979 4/19 Inspectors:

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P. Clemons, Radiation Specialist date 'si'gned date signed date signed Approved by:

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2-/ 79 u

I [. Stohr, Chief, Radiation Support date signe'd Section, FF&MS Branch Inspection Summary:

Inspection on November 7-8, 1979 (Recort No. 50-213/79-19)

Areas Inspected:

Special unannounced inspection by a regional based inspector of the licensee's response to Bulletin 79-19, including: regulatory requirements, procedures, training, audits, records of shipments and onsite observations. The inspection involved 12 inspector-hours on site by one NRC regional based inspector.

Results:

Of the six areas inspected, no items of noncompliance were identified in five areas.

One apparent item of noncompi.iance was identified in one area (Infraction - failure to comply with requirements of 10 CFR 71, Paragraph 10).

Region I Fonn 12 (Rev. April 77)

8002280 36l

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DETAILS 1.

Persons Contacted Principal Licensee Employees Mr. H. Clow, Health Physics Supervisor Mr. R. Dilaura, Quality Assurance Technician Mr. R. Graves, Plant Superintendent Mr. J. Ferguson, Station Services Superintendent The inspector also interviewed other licensee employees during the course of the inspection.

They included the Radiation-Contamination Foreman, the Radiation Protection Supervisor, the Chemist, and the Operating Supervisor.

2.

Review of Licensee's Response to IE Bulletin 79-19 The inspector reviewed Connecticut Yankee's responses to IE Bulletin 79-19 inoffice to assure that all information required by the bulletin was included, and to ascertain that corrective action commitments were also included.

3.

Organization The Health Physics Supervisor is the individual responsible for the safe transfer, packaging and transport of low level radioactive waste material.

4.

Regulatory Documents The inspector verified that the licensee has a current set of DOT and NRC regulations.

The licensee maintains a copy of 10 CFR from the U.S.

Government Printing Office, Superintendent of Documents as part of a subscription service.

This service apparently assures that the 10 CFR is maintained current.

The licensee also has a subscription to DAT-0-Line Inc. that apparently assures that the DOT regulations are maintained current.

The inspector reviewed a current invoice for the above mentioned subscription that was dated July 19, 1979.

5.

Burial Site Requirements According to a licensee representative waste shipments are made only to the burial site in South Carolina.

At the inspectors request he was shown a copy of Chem-Nuclear's License No. 097 that was issued by the State of South Carolint, and the inspector also reviewed a copy of the burial site criteri.

6.

Procedures In response to IE Bulletin 79-19, the licensee stated that management approved procedures were available to personnel involved in the transfer, packaging and transport of low level radioactive material.

The inspector verified that approved procedures have been issued to personnel involved in the tranfer, packaging and transport of low level radioactive waste.

The inspector reviewed the following procedures that had been approved by the Plant Operating Review Committee (PORC):

RAP 6.3-6 Loading & Shipment of Radioactive Waste Material, Low Specific Activity RAP 6.4-8 Radiation Exposure Control During Compacting of Dry Waste ADM 1.1-41 Radioactive Waste Management NOP 2.14-16 Dry Waste Compacting & Storing NOP 2.14-G Drumming of Evaporator Bottoms, Aerated Boron Recovery SUR 5.4-20 Radioactive Waste Sampling & Anal ;is

The above represents all procedures issued for handling radioactive waste material.

The inspector asked a licensee representative how they assured themselves that all appropriate employees had received and reviewed the above procedure.

The inspector was informed that employees are required to sign a " sign-off" sheet indicating that they had reviewed and understood the procedures.

7.

Training Auxiliary Operators, who handle the waste process system, are provided training when hired, and subsequent training are provided these individual when they are eligible for promotion.

The Auxiliary Operators are trained in the following PORC approved procedures:

Handling of Aerated Liquid, Normal Operating Procedure No. 2.14-1.

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Liquid Waste Evaporator Start-Up, Operation, and Shutdown, Normal

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Operating Procedure No. 2.14-2.

Waste Evaporator Bottoms Drumming, Noraal Operating Procedure No.

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2.14-1.

The inspector was informed by the Operating Supervisor that the Auxiliary Operators are under close supervision and periodic testing to assure their familiarity with procedures to assure safe operations.

The Auxiliary Operators are tested for waste handling operations for the primary and secondary waste generating systems.

Health Physics personnel also are involved with certain aspects involving the transfer, packaging, and transport of low level radioactive material but they have not been subjected to formalized training in the shipping, packaging, and transporation of radioactive material.

The inspector reviewed the training course attended by the Health Physics Supervisor, which according to the Supervisor was held approximately 18 months ago.

This course was devoted primarily to the regulations of the Department of Transportation.

The inspector reviewed an internal memo which indicated that appropriate health physics personnel will be subjected to a formal two week training program which includes the DOT and NRC regulatory requirements, burial site criteria, and in operatir.g procedures involving the transfer, packaging, and transportation of radioactive material as well as other radiological considerations.

According to a licensee representative this formal training will start on November 26, 1979.

The classes will be conducted in the Berlin, Connecticut office and examinations will be given according to a licensee representative.

8.

Audit Program The inspector verified that the licensee has implemented an audit program of activities associated with the transfer, packaging, and transport of low level radioactive wastes.

The inspector reviewed Quality Assurance Procedure No. QA 1.2-13.5, " Entry and Exit from Station Of Transporter For Nuclear By-Products Material (Rad Waste)." This procedure was approved by PORC on October 27, 1978.

The inspector also noted that the audit procedure was not as comprehensive as required inasmuch as the procedure addresses compacted LSA material, but the inspector also noted that the procedure was in the process of being revised to be all inclusive.

The inspector verified that an audit had been performed by Northeast Utilities Service Company on August 23, lis9, of certain activities associated with the transfer, packaging, _nd disposal of low level ra'

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active waste.

The audit did not address all regulatory requirements <

neither did it address the various aspects of trainin.

The audit did detect two deficiencies associated with 10 CFR 71, Appendix E.

The deficiencies were concerned with purchase order requirements and instructions for the handling and closing of shipping casks.

The inspector noted that corrective action had been taken on both items t the time of this inspection.

9.

Onsite Observations On November 8, 1979, the inspector selected two 55 gallon drums that were awaiting shipment, and requested the licensee to open them.

The drums, according to the licensee representative, contained evaporator bottoms solidified with cement.

The inspector verified that the radioactive contents contained in the 55 gallori drums were sclified and that there was no evidence of free standing liquid.

The inspector was informed that dewatered resins are also shipped to Barnwell for disposal.

The inspector was also told that the resins are put into a " liner," which is then dewatered.

The inspector asked if the licensee verifies that there is no free standing liquids in the " liner,"

and he was told that it is assumed there is no free standing liquids, it is not verified.

10.

Records of Shipments As the inspector reviewed shipping records on November 8, 1979, he observed a shipment made on September 19, 1979, containing approximately 9 curies of radioactive waste.

The shipment was made in the Chem-Nuclear shipping container No. LL-50-100.

The inspector requested to see a copy of the Certificate of Compliance.

The inspector was given a copy of Certificate of Compliance No. 6601, Revision 5, dated October 14, 1978.

The inspector requested copes of the documents referenced in the Certificate of Compliance.

The licensee did not have copies of drawings associated with an application dated January 29, 1974, and neither did the licensee have copies of the referenced documents dated as follows:

October 21, 1977 November 23, 1977 November 29, 1977 March 9, 1978 10 CFR 71.3, " Requirement for License," states, "No licensee subject to the regulations in this part shall (a) deliver any licensed materials to be carried for transport or (b) transport licensed material except as authorized in a general license or specific license issued by the Commission, or as exempt in this part."

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10 CFR 71.12 establishes a general license for delivery to a carrier for transport:

"(b)

In a package for which a license, certificate of compliance or other approval has been issued by the Commission's Director of Nuclear Material Safety and Safeguards or the Atomic Energy Commission, provided that:

(1) The person using a package pursuant to the general license provided by this paragraph:

(i) Has a copy of the specific license, certificate of compliance, or other approval authorizing use of the package and all documents referred to in the license, cortificate, or other approval, as applicable..."

The inspector noted that inasmuch as the shipment made on September 19, 1979 was not exempt from any requirements of 10 CFR 71, this represents noncompliance with the regulations (79-19-01).

11.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on November 8, 1979.

The inspector summarized the purpose and scope of the inspection, and the findings as presented in this report.