IR 05000244/1985001
| ML17309A356 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/07/1985 |
| From: | Dragoun T, Shanbaky M, Struckmeyer R, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17309A355 | List: |
| References | |
| 50-244-85-01, 50-244-85-1, NUDOCS 8503260006 | |
| Download: ML17309A356 (13) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-244/85-01 Docket No.
50-244 License No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Com an 89 East Avenue Rochester New York 14649 Facility Name:
R.
E. Ginna Nuclear Power Plant Inspection At:
Ontario New York Inspection Conducted:
Inspector
T. Dragoun, Radiation Sp cialist A. Weadock, Radiation S cialist d te 7 SW date R. Struckmeyer, Radiati Specialist date Approved by:
'.
M. Shan a, ief, PWR Radiation Protection ection, RPB da e
Januar 7-11 1985 Ins ection Re ort No. 50-244/85-01 Areas Ins ected:
Routine, unannounced inspection of the licensee's radioactive material transportation program including:
management controls, training and qualification of personnel, Quality Assurance, procurement, sel'ection and use of packagings, the receipt of radioactive materials, and the implementation of
CFR 61 requirements for radioactive waste generators.
The inspection involved 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> on-site by three region-based inspectors.
Results:
No violations were identified.
8503260006 8503l1 PDR ADOCK 05000244 G
DETAILS 1.0 Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewed:
1. 1 Licensee Personnel C. Anderson, Manager, Quality Assurance R. Burt, Assistant Training Coordinator D. Filkins,.Manager, Health Physics and Chemistry W. Goodman, Health Physics Foreman
"F. Mis, Health Physicist, Radioactive Waste Coordinator
- K. Nassauer, Quality Control Supervisor
"B. Quinn, Corporate Health Physicist S. Spector, Assistant Superintendent
"W. Stiewe, Quality Control Engineer
~Attended the. exit interview on January 11, 1985.
2.0
~PUr ose The purpose of this routine inspection was to review the licensee's radiation protection program with respect to the following elements:
~
Status of Previously Identified Items Control of radioactive materials transportation activities, including:
management controls training and qualification of personnel quality assurance procurement and selection of packagings use of packagings receipt of radioactive material
~
Waste form and classification, including:
waste manifests and tracking waste classification and labelling waste form quality control 3.0 Status of Previousl Identified Items 3. 1 (Closed) Violation (244/84-02-04).
Failure to develop a qualification program for QC inspectors performing verifications of transportation activities.
QC inspectors now receive specific training and qualifi-cation in the radwaste transportation area prior to performing verifi-cations of transportation activitie.2 (Closed)
Unresolved Item (244/84-02-05)
Possible failure of 1981, 1982 and 1983 audits of transportation activities to adequately address the applicable criteria of Appendix B,
CFR 50.
Review of the 1984 audit and audit plan indicated the applicable criteria of Appendix B of 10 CFR 50 were included in the audit plan and adequately reflected in the completed audit, 3.3 (Closed) Yiolation (244/84-02-03):
Failure to have procedure for solidification of radwaste approved.
The solidification procedures are described in the "Process Control Program"
~
This procedure was PORC-reviewed and approved by the Station Superintendent.
4.0 Mana ement Controls The inspector reviewed the administration and management of the licensee's radwaste and transportation of radioactive materials program.
Program responsibilities and specific job descriptions have been formalized, in administrative procedure A-201.
The radioactive waste coordinator, who reports to the manager, Health Physics and Chemistry, has direct respon-sibilityy for waste processing, storage, packaging, and shipment of radwaste.
The inspector noted that two areas of responsibility held by the radioactive waste coordinator are not mentioned in the administrative procedure:
responsibility for receipt of radioactive material and for shipments of radioactive material other than radwaste.
The licensee stated that these areas will be added to the waste coordinator's job description.
This matter will be reviewed in a future inspection (85-01-01).
5.0 Trainin and uglification of Personhel The adequacy of the licensee's training program for personnel involved with the transport of radioactive materials was measured against criteria con-tained in IE Bulletin 79-19.
It was determined that such training has been given periodically and was offered in 1980, 1981 and 1984; however,'it was determined by discussion with the assistant training coordinator that no requirement for regular retraining is specified by procedure.
A.review of attendance records and exam scores for the "Radwaste Shipping Regulations" training presented in 1984 indicated that the training was successfully com-pleted by personnel from the Health Physics, Quality Control and Maintenance Departments.
The inspector also reviewed the qualifications of several HP technicians
'erforming work associated'ith the transport of radioactive materials and found them to be qualified and signed-off on the relevant procedures.
6.0 ualit Assurance Pro ram
/
The licensee's implementation of a quality assurance program to meet the requirements of 10 CFR 71 subpart H was reviewed based on discussions with the Corporate QA manager, onsite QC personnel, and a review of relevant QC procedures and the 1984 QA audit of station Radwaste Shipment Controls.
The licensee has incorporated this QA program into the general QA program adr;.ini stered under
CFR 50, Appendix B.
The inspector verified that the Ginna Station QA Manual specifically mentions radwaste shipping activitie I The inspector reviewed the scope and findings of the 1984 Audit 884-25:5B; Ginna S ation Radioactive Waste Shipment Controls and found them to be adequate.
At.the time of this inspection the deadline for response to the findings had not been reache'd; therefore the adequacy of 'Health Physics response to the findings will be examined in a future inspection.
It was determined that the corporate auditor performing the audit had received specific training in radwaste handling and shipping.
The inspector determined that the on-site QC department is heavily involved in routine transportation activities.
QC inspectors are required to be certified in the area of radwaste transportation prior to performing veri-fications of transportation activities.
This certification has been in" eluded in t'heir inspector qualification program and is based on the suc-cessful completion of specific training.
Currently, 11 out of 13 total inspectors are certified to perform transportation verifications.
On-site QC activities in the transportation area include performing receipt inspection of packagings, verifications during package use, and verifying
.
package integrity, labeling, and loading prior to shipment.
Final QC review of all procedural sign-offs is required before a radwaste shipment leaves site.
The QC department maintains controlled copies of their packaging vendor procedures and has closely followed these procedures in developing their in-house inspection procedures.
It was noted, however, that formal QC involvement does not extend to shipments of radioactive material other than radwaste shipments; QC over sight of these shipments has been informal and sporadic.
The licencee stated that the applicable procedures would be revised to extend QC involvement to these shipments (244/85-01-04).
Within the scope of this review, no violations were identified.
7:0 Procurement and Selection of Packa in s
The licensee program for selection and procurement of packages was reviewed against the following criteria:
CFR 71. 12, "General License:
NRC Approved Package"
~
CFR 173, "Shippers - General Requirements for Shipments and Packagings"
CFR 50, Appendix B, Criterion IV, "Procurement Document Control" The licensee's performance relative to these criteria was determined by reviewing transport package documentation and discussion with licensee personnel.
Requirements and purchase orders for shipping containers are generated by the Radioactive Waste Coordinator.
On-site QC personnel perform receipt inspections of the packagings (see section 6.0).
Cl 8jI
I The inspector reviewed Certificates of Compliance for the High Integrity
'Containers (HICs) maintained on site and found them to be complete and in order.
Support documentation for the Certificates of Compliance, including user registration, manufacturer's use and inspection recommendations, and technical design information and drawings was also maintained by the licensee.
Visual inspection of on-site HICs indicated they were being stored and maintained in accordance with the Certificate of Compliance.
Within the scope of this review, no violations were identified.
8.0 Use of Packa in s
The licensee'
program for the use of packages and deli very to carriers was reviewed against the criteria in
CFR 71 and
CFR 172 through 178.
The licensee's performance relative to these criteria was determined by interview of licensee personnel, observation of the waste compaction.
operation, tour of the radwaste storage building, and review of relevant procedures and shipment records for 1984.
During the scope of the above review, it was noted that the licensee ma'de 39 shipments of radioactive material in 1984; 19 were radwaste shipments for burial, and 20 were non-radwaste shipment's of samples to various vendors.
The inspector reviewed the records of the 20 non-radwaste shipments, along with the licensee's copy of the various receiver's licenses to receive radioactive materials, and identified the following problems:
a.
b.
Shipment ¹84-9 was made to SAI with an activity on the manifest greater than that allowed by SAI's license.
Shipment ¹84-28 was made to NWT although the licensee's copy of NWT's license had expired in 1982 c.
Shipments were made to the University of Lowell and Brockport State University and the 1'icensee was not immediately able to produce copies of their license.
During the course of the week, the licensee produced current licenses and documentation to indicate shipment ¹84-9 had been mislabelled as to activ-ity on the manifest.
The above occurrences indicate, however, that refer-ence to the receiver's license was not being made prior to these special-ized non-radwaste shipments.
The licensee indicated that procedures for shipment of radioactive materials other than radwaste would be revised to include checks to insure the receiver is licensed and the material shipped is within license limits.
This area will be reviewed during a subsequent inspection (244/85-01-02).
The inspector also reviewed documentation for the 19 radwaste shipments intended for burial that were made in 1984.
A specific shipment of spent resin sent to Barnwell was reviewed in depth to determine whether all required information was present and being maintained by the licensee.
The inspector verified that the manifests and Bill of Lading were correct,
surveys were adequate, all gC checks were performed, and all radionu"lide identifications and thermowatt calculations necessary to show compliance with the Certifica.e of Compliance were performed.
The inspector reviewed various station procedures pertaining to the ship-ment of radioactive materials including:
RD-10,0 "Preparing Radioactive Material for Shipment or Storage" RD-10.1 "States and Federal Requirements for the Shipment of Large (}uantities of Radi oacti ve.Materi al s" RD-10.2 "Radwaste Shipping to CNSI at the Barnwell, SC Site" RD-10.4. 1 "U.S. Ecology Radioactive Shipment Record" During the above review it was noted that no provision in the procedures exists to initiate a timetable and ensure the licensee conducts an investi-gation of any shipment for which acknowledgement of receipt has not been received within the time limits prescribed in 10 CFR 20311.
This item will be combined and tracked with an item described in Section 9.0 and will be reviewed during a subsequent inspection (244j85-01-03).
9.0 Recei t of Radioactive Materials I.
The licensee's ro ram o t e p
g f r h
receipt of radioactive material was reviewed against criteria contained in.10 CFR 20.205 and procedure RD-11, "Receipt of Radioact,ive Materials".
The licensee's performance relative to these criteria was determined by interview of licensee personnel and review of Bills of Lading and associated surveys for shipments of radioactive mater-ials received during 1984.
h'ithin the scope of this review, no viol'ations were identified.
However, it was noted that sufficient documentation was not being kept by the licen-see to verify that incoming packages were being surveyed within the time limits prescribed by 10 CFR 20.205 i.e., within three hours if receipt of material is during normal working hours; within eighteen hours if receipt is after normal working hours.
Surveys performed by the licensee indicated only the time of the survey; the time of actual receipt of the material was not logged by the licensee.
The licensee indicated the relevant proce-dure would be revised to require documentation of time of material receipt and survey.
The licensee's proposed revision of procedures to provide a timetable for tracking outgoing shipments (Sections 8.0)
and the timely performance of receipt material surveys will be reviewed during a subsequent inspectio.0 Waste Form and Classification
.The licensee's program for low-level solid radioactive waste management was reviewed against the criteria contained in
CFR Parts 20.311
, 61.55, and 61.56.
10.1 Maste Nanifests and Trackin The inspector reviewed selected shipping papers and waste manifests for 1984, and noted that the manifests generally met the requirements of 10 CFR 20.311(b), with one exception:
Manifests accompanying ship-ments of low-level radwaste to U.S.
Ecolooy in Richland, Washinaton.
did not contain the address and phone number (or EPA hazardous waste identification number) of the organi zation that transported the ship-ments to the disposal facility.
The licensee indicated that this was due to an oversight in the computer program that is used to generate these manifests, and that this would be corrected prior to further shipment to this facility.
This will be reviewed in a future inspec-tion (50-244/85-01-05).
Although no formal tracking method was in place (see Section 8), the licensee received a written acknowledgement of receipt of each shipment within the 20 day period specified by 10 CFR 20.311(h).
The licensee maintains current copies of the site disposal conditions and copies of the burial-site licenses issued by the respective states.
10.2 Waste Classification and Labelli'n The licensee's program for classification and labelling of radwasts was reviewed against criteria contained in 10 CFR 61.55, 61.56, and 61.57, and in the Low-Level Waste Licensing Branch technical position papers on Waste Classification and on Maste Form.
The licensee has identified and sampled the waste streams.
Scaling factors have been developed based on waste stream analyses performed by Science Applications, Inc.
Currently, sampling is being performed twice annually.
It is planned to reduce the frequency to an annual basis after the initial program for waste stream characterization has been completed.
The inspector reviewed the licensee's procedure RD-10.8,
"10 CFR 61 Compliance",
and found that it adequately covered the regulatory requirements for classifying radioactive solid waste.
The inspector also reviewed selected manifests with respect to the classification
. criteria contained in 10 CFR 61.55 and in Procedure RD-10.8.
This review indicated that the licensee is carrying out a program to assure proper classification of radwast I yt
!.
The inspector toured the licensee's radwaste'storage area, where drums and boxes are subjected to gC inspection and stored until shipment.
Packages
.had been labeled with the waste classification per
CFR 61.57.
10.3 Waste Form 10.4 The inspector reviewed the
CFR 61.56 waste form requirements with the licensee, and toured the licensee's facilities for waste compacting, solidificati.on, and storage.
The licensee's procedures contain provi-sions for ensuring that the waste form requirements are met.
The licensee stated that waste streams from the Ginna station contain no toxic 'gases or pathogenic material; nor are they explosive or pyro-phoric.
The minimum requirements for waste form, given in 10 CFR 61.56(a),
are met by the type of packaging and by ensuring that the liquid content of packages is minimized.
Wastes are packaged for dis-posal in metal and/or high-integrity containers.
Liquid wastes are solidified in cement as necessary, or packaged in absorbent material.
The stability requirements of 10 CFR 61.56(b),
which apply to Class B
and Class C wastes, are met primarily by solidification of liquid wastes.
All waste packages are inspected by guality Control personnel prior to shipment to ensure that no detectable free standing liquid is present.
Qualit Control 11.0 Exit The licensee's implementation of a quality control program as required by 10 CFR 20.311(d)
to assure compliance with 10 CFR 61.55 and 61.56, was reviewed.
equality Control personnel check each package of radwaste prior to shipment with respect to the waste characteristics (form),
and thereby meet the intent of 10 CFR 61.56.
However, these personnel have not received sufficient training to enable them to review the waste classification process and certify that waste has been properly classified according to the criteria of 10 CFR 61.55.
Training of gC personnel and their participation in this activity will be reviewed in a future inspection (244/85-01-06).
Interview The inspectors met with the licensee personnel denoted in Section 1.0 on
'January 11, 1985., to discuss the scope and findings of this inspection.
At no time during this inspection was written material provided to the licensee by the NRC inspector s