IR 05000244/1981020
| ML17258A384 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/13/1981 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17258A383 | List: |
| References | |
| 50-244-81-20, NUDOCS 8112230566 | |
| Download: ML17258A384 (16) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No..
50-244/81-20 Docket No.
50-244 License No.
Licensee:
Priority Rochester Gas and Electric Company 89 East Avenue Category Rochester, New York 14649 Faci 1 ity Name R.
E.
Gi nna Nucl ear Power Pl ant Ontario, New York Inspection at:
r Inspection conducted:
October 5 to 9, 1981
'nspectors:
m ee, a )a son pecsa sst-date signed date signed date signed Approved by:
(- 6-P. J.
Knapp, Chi ef, aci 1 ity
.
diation Protection Section, Technical Inspection Branch Ins ection Summar
Inspection on October 5-9, 1981 Reoort No. 50-244/81-20
~A:
i di p
i b,i ibdi <<h transportation program maintained to ensure safe receipt, packaging, delivery to a carrier, and transport of licensed radioactive materials, includina:
oraaniration; quality assurance; procedures; training; audits; selection of packaging; preparation of packages for shipment; delivery of completed packages to carriers; receipt of packages; incident reporting; examination of packages; and shippinq records.
This inspection involved 30 inspector-hours on site by one NRC regional based inspector.
Results:
No items of noncompliance were identified.
e Region I Form 12 (Rev. April 77)
ADOCK 05000244 enRt
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DETAILS 1.
Persons Contacted C. Anderson, Manager of Quality Assurance
- J. Bodine, Quality Control Engineer
- D. Fi lkins, Supervisor of Health Physics and Chemistry P.
Fi lion, Environmental and Radiochemistry Supervisor
~F. Mis, Health Physicist
"K. Nassauer, Quality Control Technician
- J. Noon, Assistant Plant Superintendent
- B. Quinn, Health Physicist (Operations Foreman)
"B. Snow, Plant Superintendent R. Watts, Corporate Health Physicist
- Denotes presence at the exit interview, October 9, 1981.
2.
Overview of Licensee Radwaste Trans ortation Activities Durin 1980 and 1981 throu h Se tember a.
Ty e B and Lar e uantit Shi ments Totalin about 400-600 Ci er ear The licensee shipped two containers of spent resin during 1980, holding about 278 and 133 Ci of low specific activity (LSA) Transport Groups III and IY radioactive materials, to Barnwell, South Carolina.
During the first nine months of 1981 the licensee shipped one container of spent resin holdi.ng about 620 Ci of LSA Transport Groups III and IV radioactive mat'erials to Barnwell, South Carolina.
Each of these containers was a CNSI-8-120, Model LL 50-100 container used under a Certificate of Compliance.
b.
T e A uantit Shi ments Totalin About 25 Ci er ear The Barnwell, South Carolina waste burial site waste volume allocation is less than one full transport load each month for Ginna.
However, full loads are possible when unused allocations become available.
In addition the licensee shipped one transport load to the Beatty, Nevada waste burial site during 1980 and another on September 28, 1981..
The monthly shipments of containers of no greater than Type A quantities of radwaste averaged about as follows:
CT T
T~C T
ical Contents
~C.'
C Less than
Less than
Less than 0.1 Less than
55-gallon drum Solidified liquid radwaste
55-gallon drums Spent filters (shipped in cement)
55-gallon drums Miscellaneous
95 Cu. ft. (gA-B-25)"""
Compacted dry active waste
Usually within the quantity listed.
~*
Varies from month to month.
- "" Steel Box.
The vendor certified that test specimen passed tests per
CFR 71 Appendix A.
In addition to the above there was an occasional shipment of a 160 cu. ft. or a 300 cu. ft. liner.
About a dozen containers per year of contaminated equipment, samples, radioactive sources, etc.,
were received on site or shipped offsite with detectible radioactive contents.
For example, shipments were between power plants or between Ginna and repair facilities.
The licensee has commenced the construction of a building for low level waste temporary storage.
Presently waste is placed in trailers as full loads accumulate in preparation for shipment.
No items of noncomp 1 i ance were ident ified.
3.
Review of the Mana ement Controls of the Trans ortation Pro ram
'a
~
Or anization Res onsibilities and Authorities The inspector reviewed the documents listed below, and interviewed personnel, to verify that the organization, responsibilities, and authorities of personnel involved in the packaging, preparation for transport, and transport of radioactive material were clearly designated.
Technical Specifications Organization Chart Meeting Minutes dated June 19, 1980, September 23, 1980, January 21, 1981, and July 22, 1981, for the Low Level Radwaste Task Group Licensee procedures (paragraph 2b)
A licensee representative stated that no written management program designated all of the actual duties.
He gave the follow-ing description of these assignment The organization given in the Technical Specifications controls the operations on site, with review and guidance by the Task Group in the area of radwaste operations and transportation.
The Supervisor, Chemistry and Health Physics, is responsible for the management of radioactive materials on site, including the pro-cedures for shipping.
A health physicist, under his supervision, and a quality control technician approve each radioactive materials container for shipment off site, and each transport vehicle involved in an exclusive use shipment.
The health physicist coordinates and schedules the activities necessary to ship radioactive materials.
He (and his supervisors)
have the following responsibi 1,ity of maintaining the:
Records of transfers and shipments.
Required copies of documents, procedures, regulations, certificates, licenses and drawings.
Burial site allocations, permits, criteria, notifications and correspondence.
Government agency contacts, registrations, certificates, licenses and correspondence.
Vehicle routing, transportation permits, contracts and schedules.
Oocumentation of container acceptability, labels, and surveys.
Vehicle surveys and placards.
Final clearance for each vehicle to transport radioactive materials offsite.
Receiving surveys for radioactive material packages and shipments.
The remaining responsibilities are carried out by other personnel as listed below.
Radwaste Task Group Initiation of corporate policy changes.
Radwaste system improvements.
Review of radwaste transportation.
Radwaste reductio Operations Radwaste system operation.
Dewatering of spent resin containers.
Solidification of liquid radwaste (Eventually now done by contractors).
Chemi stry Services Samples and analyses.
Routine housekeeping, cleaning and decontamination.
Collection and disposition of miscellaneous noncontaminated and contaminated tools, laundry, trash, etc.
Preparation (i.e.,
drumming, compacting, or boxing up) of dry active radwaste for storage or shipment.
Maintenance guality Control Loading, unloading or mov'ing of casks, etc.
Repairs and mechanical adjustments to equipment.
Independent audits of the above activities guality Control of contracted supplies and services.
gC of purchased or leased equipment.
guality controls of processes and maintenance performed on site.
Inspection of transport vehicles for roadworthi-ness.
Inspection of radioactive shipments and transport.
vehicles for compliance with NRC and DOT regulations.
The licensee's control of the contractor's performance of liquid radwaste solidification consisted of the contract for the conduct of the services rendered, and a test of each solidified waste container.
This involved NUMANCO personnel, equipment, and procedures.
No items of noncompliance were identified.
b.
Procedures for the Recei t Packa in and Trans ort of Radioactive Materials The inspector reviewed the procedures, reports and other documents listed belo Procedure, Re ort No. etc.
Abbrev iated Title A-1 A-2.1 A-102 A-1001 A-1002 M-18.6 PCN 81-T-405 QCIP-21 QCIP-31 RD-9 RD-10 RD-10.1-10.8 S-4.1.25.1 ST-816 EWR-2414 NIS-81-370 July 1, 1978 Radiation Control Manual Receiving, Inventory, Shipment of Fuel Administrative and Engineering Staff Responsibilities
'Inspection and Surveillance Activities Qualification of Surveillance and Inspection Personnel Handling, Loading, Unloading of CNSI Cask CNS-8-120 (Model LL-50-100)
Procedure RD 10.4 change Shipping Package CNS-8-,120 Inspection Shipping Package CNS-1608 Inspection Preparing Waste for Shipment or Storage Shipping Radioactive Material Radioactive Material Shipment Records and Forms Checking Drums for Free Standing Liquid Special Test (Solidification)
Final Report by Catalytic, Inc.
"R.
E. Ginna Radwaste Study" Nevada Inspection Services Audit of Ginna, September 15, 1981 Current Corporate Statement of QA Policy Quality Assurance Manual, Introduction, Shipping and Packaging Audits of Chem Nuclear by Ginna QA, May 16, 1979 and May 28 and 29, 1980 Chemistry Logbook (Waste Shipments)
1981 NUMANCO Solidification Procedure and Process Control Program, April 16, 1981 The inspector verified that the procedures implemented the NRC and DOT regulatory requirements'any of the operational procedures listed above required the use of checklists which included QC hold points.
A signoff was required on each checklist item.
Completed checklists wer e retained in the shipping record file.
The inspector also reviewed an example of the steps followed in the implementation of a procedure change.
Observation of work in progress, and the review of shipping records, did not identify any failure to adhere to the procedures.
No items of noncompliance were identifie c.
Indoctrination and Trainin on NRC and DOT Trans ortation Re uirements The inspector reviewed the licensee's adherence to the training commitments in the response to NRC IE Bulletin No. 79-19, dated September 25, 1979.
A licensee representative stated that there were no procedures establishing the entire training program in this area and there was no-formal statement of the program purpose.
Records of the training during 1981 were on file.
The records indicated that:
The health physicist had attended a two day ASME/EPRI Radwaste Workshop, February, 1981.
The remaining 23 personnel involved in radwaste transportation had attended on-site training on September 16 or 23, 1981.
The Auxiliary Operators training/retraining were up to date as required for radwaste system operations.
The existing training outline and lesson plans appeared to include the appropriate information.
Training attendance sheets verified the presence of the appropriate personnel.
No examinations or pass-fail criteria were identified other than the supervisor's observation of on-the-job capabilities of these individuals.
No items of noncompliance were identified.
d.
Audits of Trans ortation Activities The inspector reviewed the licensee's audit program to verify there was a planned program for periodic audits of transportation activities.
The Low Level Radwaste Task Group reviewed these activities four times during 1980 and 1981.
There was no formal statement of the meeting frequency.
The notices of meetings indicated in each case a
number of developments requiring consideration rather than routine periodic meetings scheduled primarily to audit the program.
Procedure No. A-1001 specified the surveillance by gC over trans-portation activities of the category described in paragraph 2a, above, and gC surveillance was performed pursuant to gCIP-21, in each of these examples.
This was a routine licensee activity, limited to specific areas of the progra On May 28 and 29, 1980 the licensee gA organization conducted an audit of the guality Assurance Program maintained by Chem Nuclear, Inc. through a visit to the Barnwell, South Carolina waste burial site.
This was a routine licensee activity, in a limited area of the program.
Nevada Inspection Services, Inc., performed an audit of the licensee's transportation program on site on September 15, 1981.
This was a state-imposed condition on shipping to the Beatty, Nevada, waste burial site.
The licensee did not identify any schedule of continuing periodic audits of the transportation program.
No items of noncompliance were identified.
e.
Review of the Im lementation of the ualit Assurance Pro ram A
roved Pursuant to
CFR 71.51 a
The inspector verified that the quality assurance program was documented and implemented by review of the following:
Approval number 0019, March 23, 1979, "guality Assurance Program Approval for Radioactive Material Packages,"
and the corporate statement, the guality Assurance Manual and procedures A-1001 and A-1002 listed in Section 3b of this report.
Various completed checklists for the shipments and containers described in paragraph 2a of this report.
No items of noncompliance were identified.
4.
Selection Procurement and Reuse of Packa in The licensee maintains an approved gA Program, (described above)
and a
list of qualified vendors.
The licensee controls the procurement of type A and type B packaging under that program.
Review of the: vendors'iterature, manuals, and contractual agreements verified the inclusion of assurance that the vendor s complied with DOT and NRC regulations.
Examination of empty DOT 17H 55-gallon drums and DOT Type A Specification 7A 96 cu. ft. metal shipping containers (B-25) stored outdoors onsite revealed no problem The inspector also reviewed copies of the Certificates of Compliance, user's registrations, QA/QC records, and shipping records for the shipments described in paragraph 2a.
The inspector examined licensee procedures which applied to the reuse of those radioactive material shipping containers and packaging that were identified onsite or in the shipping records.
These included:
New fuel shipping containers (typically returned empty to the supplier but could return a reject fuel element).
Shielded shipping casks used to transport loaded cask liners to burial sites.
Containers for tools and equipment used in the controlled area.
A licensee representative stated that no foreign made packaging or packaging with an outside dimension as small as four inches was used.
He said that no special form radioactive material or plutonium was shipped during 1980 or 1981 to date.
The health physicist stated that all material released from the controlled area was checked for detectible radioactivity and contamination before release.
The procedures provided for control of all quantities of radio-active materials.
The inspector noted that the HP technician on the job during the loading of vehicles was required to check each container or package.
The inspector observed the preparation of two exclusive use trailers for transport of low specific activity (LSA) radioactive materials to a burial site.
The inspector reviewed shipping procedures and the completed checklists to verify marking, placarding, securing of the load, and radiation levels.
No items of noncompliance were identified.
5.
Control of the Pre aration of Packa es for Shi ment and Deliver to Carriers The health physicist used written procedures and checklists and signed certifications that the following were in order for each shipment requiring such documentation:
Packaging QA/QC documentation Packaging in good condition
Package closure and seal s Mounting and tiedown of containers to vehicles HP survey, contamination and radiation level No liquid radioactive materials other than exempt quantities, for sample analyses, were identified in the records of shipments offsite.
The inspector noted that the procedures specify proper labelling, marking, and placarding; and the licensee adhered to the procedures as observed during the preparation of two shipments.
No items of noncompliance were identified.
6.
Descri tion of Packa in Contents and Classification The inspector verified that the licensee procedures included the criteria and action levels necessary to comply with the regulatory requirements regarding the DOT shipping name, class of materials, identification of isotopes, description of physical and chemical form, quantity of radioactive material, heat load, package label, package transport index, package identification and certification and shipping instructions.
Review of shipping records verified the licensee's adherence to these procedures (see paragraph 9).
The licensee representative stated that there were no plans to ship plutonium other than that incidental to spent fuel.
Fuel might be shipped in small amounts for purpose of examination.
Examination of several packages loaded on transports for shipment did not identify any items of noncompliance.
7.
Control of Pre aration of the Trans ort Vehicle for De arture The inspector observed that, in accordance with the procedures, the health physicist controlled the scheduling, loading and departure of transport vehicles carrying radioactive materials.
He verified the container closure and tiedown to the transport vehicle.
The certification of proper preparation was kept with the shipping records.
The contract requires the broker's or the driver's independent verification of the status of the containers and contracted vehicles before departure.
No items of noncompliance were identifie.
Notifications to Consi nees and as necessar to DOT and NRC The inspector verified by review of shipping records that radioactive material shipment notifications were made to the consignees in accordance with procedures.
The exclusive use carriers were contracted to independently notify the transferee of any changes in the arrival time and to reconfirm the arrival time on the day before the arrival.
The contract also required notification.of the reactor licensee, DOT, NRC and state and local authorities in the event of a transportation accident.
No items of noncompliance were identified.
9.
Review of Shi in Records The inspector reviewed radioactive material receipt and shipping records to verify that the licensee adhered to procedures and complied with regulatory requirements concerning:
Authorization to depart the site; Surveys, radiation levels and contamination; QC inspections and checklists; Maintenance; Package identification and marking; Applicable procedures for package use; Package certification number; Filling and loading of packages; Proper contents of packages;
.Closure and securement of package; Special instructions for package use; Shippers certifications and criteria for acceptance; Shipping instructions; Inspection of contents of packages;
Identification of transferee; Destination and routing of shipment; Shipment dates; Incident reports.
The inspector reviewed the following licensee radioactive materials receiving and shipping records:
Chemistry log book shipments; Radioactive material receipt folder; Radioactive waste and radioactive material shipping folder; Samples of shipping records for 1980 (80-1 to 80-38, and 1981 (81-1 to 81-24)
The above shipping records covered tools and equipment, LSA, and small liquid samples.
The greatest quantity shipped recently in a single shipment was 620.5 Ci of LSA (spent resins)
in shipment No. 81-08, April 3, 1981.
This quantity consisted of 234 Ci of CS-137, 96 Ci of Cs-134, 201 Ci of Co-60, and 90 Ci of less prominent radioisotopes.
The indicated ratio of Cs-137/Sr 90 was approximately 545/1, thus about 0.4 Ci of Sr-90 was present.
Review of records of ten Type A and three Type B shipments (one in 1981)
did not identify any problems.
No items of noncompliance were identified.
10.
Exit Interview The inspector met with the licensee representatives, denoted in para-graph 1, at the conclusion of the inspection, to review the inspection findings.