IR 05000271/1987001

Insp Rept 50-271/87-01 on 870112-16.Violation Noted:Failure to Identify Radionuclide Activity on Shipping Manifest

ML20211F965
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/16/1987
From:	Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211F930	List: IR 05000271/1987001 ML20211F926
References
50-271-87-01, 50-271-87-1, NUDOCS 8702250241
Download: ML20211F965 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-271/87-01 Docket No.

50-271 License No. DPR-28 Priority

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Category C

Licensee:

Vermont Yankee Nuclear Power Corporation R.D. #5, Box 169, Ferry Road Brattleboro, Vermont 05301 Facility Name:

Vermont Yankee Nuclear Power Station Inspection At:

Vernon, Vermont Inspection Conducted: January 12-16, 1987

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Inspectors:

b d hd4AA 4//G[77 M. Mill Senior Radiation Specialist cfate Approved by:

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W. Pas'efak, Chief

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Effluents Radiation Protection Section A

Inspection Summary: Inspection on January 12-16, 1987 (Report No. 50-271/87-01)

Areas Inspected:

Routine, unannounced safety inspection of the licensee's -

radioactive waste management program including: previously identified item, radioactive material transportation, radioactive waste characterization and classification, and quality assurance / quality control.

Results: One violation was observed: failure to identify a radionuclide activity on the shipping manifest. However, the violation was licensee identi-fied, paragraph 3.3.

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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel

• J. Pelletier, Plant Manager

• D. Reid, Operations Superintendent

• B. Leach, Chemistry and Health Physics Supervisor

• R. Morrisette, Plant Health Physicist D. Dyer, Lead Engineer, Operations Quality Assurance

• E. Porter, C&HP Assistant (Radwaste Coordinator)

P. Manely, Alternate Radwaste Coordinator 1.2 NRC Personnel

• W. Raymond, Senior Resident Inspector

• Attended the exit interview on January 16, 1987.

2.0 Previously Identified Item (Closed) Inspector Follow-up Item (50-271/85-24-01):

Formalize peer review process for quality assurance related to transportation activities.

The licensee continues to perform independent quality assurance surveil-lances of radioactive material shipments by the Operations Quality Group.

The licensee does not use a peer review Quality Assurance program to implement the Quality Assurance Program fortransport packages.

Super-visory and peer review of all radioactive waste shipping records and waste characterization was being implemented in accordance with procedure OP-2511, "Radwaste Cask, Drum and Box Handling", Revision 11 to meet quality control requirements.

3.0 Radioactive Material Transportation 3.1 Radioactive Waste Controls The licensee maintains a complete inventory of radioactive material and contaminated materials onsite.

Status logs indicating total radioactiv-ity, volume and dose rate are used to prepare for shipment of dry active waste (DAW) packages.

Liquids are also tracked with regard to volume and location. Most radioactive material is temporarily stored in the North Warehouse.

The inspector questioned if a safety evaluation for the storage of radioactive liquids had been prepared and reviewed.

The licensee stated that an earlier safety evaluation for storage of hazardous liquids had been completed, but it did not specifically address radio-active liquids. The inspector requested that the licensee document their evaluation of the storage of radioactive material in the North Warehouse.

Concerning volume reduction efforts, the licensee instituted a sand blasting operation to remove contamination and reduce dry active waste

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volumes.

Indoctrination of plant personnel, who operate the radwaste systems, included discussions on volume reduction and cost constraints to stress the importance of efficient radwaste processing. The licensee's radwaste goal for 1987 is 10,000 ft3 based on a projected 12,030 ft3 of DAW and spent resins. A total of 11,475 ft3 of radwaste was shipped

during 1986.

3.2 -Package Selection The licensee's program for selection of packages was examined against the requirements of 10 CFR 71.87 and within the framework of the DOT require-ments of 49 CFR Part 173.

For dry radioactive waste, the licensee used metal and wood boxes or steel drums, as strong tight containers.

Dewatered resins and radioactive material shipments, such as irradiated reactor components, requiring the use of an NRC certified package (outer container) were made in vendor supplied casks and in a licensee owned cask, previously NUS14-170. Copies of the Certificate of Compliance including drawings and maintenance pro-cedures were available for all Type A and Type B casks in use.

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The licensee maintained the VY cask with regard to minor repairs, leak rate testing, and quality assurance surveillances.

Within the scope of this review, no violations were identified.

3.3 Shipment of Radioactive Materials

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The transportation of licensed material was reviewed against the criteria contained in 10 CFR 71, " Packaging and Transportation of Radioactive i

Material, "10 CFR 20.311(d)(3), " Transfer for disposal and manifests," 10 CFR 61.55, " Waste Classification," and 10 CFR 61.56, " Waste

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Characteristics."

l The licensee's performance relative to these criteria was determined by l

the following:

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discussions with the Radwaste and Alternate Radwaste Coordinators;

review of fourteen shipping manifests and related documentation from 1986

review of two program procedures, OP-2511, Revision, "Radwaste Cask, Drum and Box Handling", and AP-0504, Revision 12, " Shipment and Receipt of Radioactive Materials".

review of vendor analysis reports for waste stream samples for 1985 and 1986

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• review of computerized waste classification and waste type acceptance criteria.

Within the scope of this review, one violation was observed. However, the licensee had identified the violation and corrected the problem in September.1986.

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10 CFR 20.311(b) requires that manifests accompanying radioactive waste shipments indicate as completely as practicable the radionuclide identity and quantity and total radioactivity of the shipment.

The licensee failed to identify the radionuclide Iron-55, its activity and by the omission of Iron-55, the total radioactivity of the manifest from eight DAW shipments made between January 24 and June 27, 1986. The licensee had knowledge of a positive correlation between cobalt-60 and Iron-55 (i.e., scaling factor from cobalt of 3.49 for DAW), since January 14, 1986. This is when they received one of two vendor analysis reports for smear samples taken in October 1985. A second vendor analysis had reported for Iron-55 less than minimal detectable activity for the same sample period.

The licensee reviewed the data from both vendors and determined to take the conservative approach and assume Iron-55 was in the waste stream.

The licensee implemented an approved waste classification methodology in September 1986 and included the Iron-55 correlation at that time.

While the inclusion of Iron-55 was appropriate, implementation should have been more timely. The licensee stated that the 1986 smear samples results will be reviewed and updates, if required, to the scaling factors would be made in a more timely manner.

No additional corrective actions were required.

The inspector also noted that the determination of radioactivity from DAW in non-standard packages and fuel pool skimmer filters should be reviewed.

The calculation appears to be conservative, but should be corrected to address standard methods for determination of gross activity from dose rate measurements. This item will be reviewed during a subsequent in-spection (50-271/87-01-01).

A strength of the radwaste management program was noted by the inspector.

Records relating to shipping documentation, waste stream analysis and cask maintenance were extremely well maintained.

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Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a QA program for the packaging and transportation of radioactive materials. A commission approved QA program which satisfies the applicable criteria of Appendix B to 10 CFR 50 and which is established, maintained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.

The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radioactive materials.

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The licensee's performance relative to this criteria was determined from discussions with the Lead Engineer, Operations Quality Group, Plant Health-Physicist, Radwaste Coordinator and the QA surveillance reports and QA audit report for 1986 with regard to radioactive waste processing and transport packages.

The Operations Quality Group performs surveillances of packaging and shipping activities. Twenty-five surveillances were conducted on the fifty-five radioactive material shipments.

No problems were identified.

The same group with outside technical specialists conducted an annual audit of radwaste shipping, waste classification, waste packaging and maintenance of NRC approved transport packages. The audit report noted one deficiency related to required review of procedure AP-0503. The audit was thorough and provided a checklist to indicate the scope of the audit based on the applicable criteria of 10 CFR 50 Appendix B.

The licensee's performance in the conduct of a QA program under 10 CFR 20.31(d)(3) was determined by review of procedures for preparing radwaste shipments, examination of the peer review, QC sign-offs related to shipments of dewatered resins and review of QA audits, which performed independent determinations of waste classification under 10 CFR 61.55.

Within the scope of this review, no violations were identified.

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Exit Interview The inspector met with the licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on January 16, 1987. The inspector summarized the scope of the inspection and findings.

At no time during this inspection was written material provided to the licensee.