IR 05000271/1988017

Insp Rept 50-271/88-17 on 880926-30.No Violations Noted. Major Areas Inspected:Licensee Radwaste Program,Including Training of Personnel,Procurement of Packaging,Delivery to Carriers,Records & Repts & Waste Classification & Labeling

ML20205P746
Person / Time
Site:	Vermont Yankee
Issue date:	10/21/1988
From:	Davidson B, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205P744	List: IR 05000271/1988017 ML20205P740
References
50-271-88-17, NUDOCS 8811080279
Download: ML20205P746 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report N /88-17 Docket No. _50-271 License No. DPR-28 Priority -

Category _C__

Licensee: Vermont Yankee Nuclear Power Corpcration 5 Ferry Road

'Brattleboro, Yankee Facility Name: Vermont Yankee Inspection At: Vernon Vermont Inspection Conducted: September 26-30, 1988

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Ir.spectors: AJC U kRadiation M (a C, El I arry S. David Specialist dateil Approved by: c ( (D

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ru Walter J. Pasciah die , Effluents Radiation hl . l

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N Protection Sectio % FRSSB, DRSS

Inspection Summa : Inspection on September 26-30; 1988 (Report (

No. 50Tf7U81R7 Areas Inspected: Routine, announced inspection of the licensee's radioactivo waste program including training of personnel, procurement of packaging, delivery to carriers, records and reports, waste classification and labelin Results: No violations were identified. An effective program for characterization, cla uification, and shipping radioactive waste was foun Os11000279 001020 gDR ADOCK 05000273 PNU

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DETAILS 1.0 Personnel Contacted During the course of this routine inspection, the following personnel were contacted or interviewe .1 Licensee Personnel

• R. Leach, Radiation Protection Supervisor

• R. Pagodin, Technical Services Superintendent

• S. Jefferson, Assistant to Plant Manager

• R. Wanczyk, Operations Superintendent

• A.'Chesley, Simulator Supervisor

• P. Manley, Radwaste Coordinator

• 0 Oyer, Quality Services G. Johnson, Operations Supervisor J. Ainsworth, Operations Training Instructor F. Burger, Receipt Inspection Other licensee personnel were contacted or interviewed during this inspectio . . ! NRC personnel

• G. Grant, Senior Resident Inspector

• J. Macdonald, Resident Inspector

• Denotes those individuals who attended the exit interview on September 30, 198 .0 Actions on Previously Identified Items 2.1 (Closed) Inspection Follow-up Item (271/87-01-01). Review curie conversion factors for non-standard packages. The inspector reviewed the factor calculation methnd for packages with dimensions less than tw1 feet on any side and found the method adequate. This item is clo',e .0 Sc_oge of the Inspection The puroose of this routine inspection was to review the licensee's solid radioactive waste (radwaste) preparation, packaging and shipping program as implemsnted by the licensee from January 1, 1988, through September 30, 1988. During the period, the licensee made 37 shipments of radwaste for disposal. Eleven of these shipments were reviewed in detail in the following areas:

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Control of radioactive material transportation including:

• Training and qualification of personnel;

' Quality Assurance;

' Procurement and selection of packaging;

• Use of packages and delivery to carriers; and

' Records and report Control of low-level waste disposal, including:

• 0rganization

• Quality Control

• Waste Manifes's and tracking; and

' Waste charactarization and classificatio .0 Management Controls 4.1 Organization The licensee's Radiation Protection Supervisor has the overall responsibility for the radwaste shipping program. The licensee's Operations Supervisor is responsible for the operation of plant equipment such as resin centrifuge dewatering equipment and the compacto A health physicist, assigned as the Radwaste Coordinator, is responsible for the day to day activities and program implementa-tion. This individual performs calculations to support waste manifest radionuclide activities and classification under 10 CFR 61.55. Site specificscalingfactorsforwastestreamsareevaluatedannually by the licensee s radionalytical support organization. A vendor laboratory is used to confirm these result Receipt inspection personnel evaluate casks and liners, quality control personnel perform survetilances on manifest preparation, vehicle inspection and cask handling, and quality assurance personnel perform programmatic audits of the radwaste are Within the scope of this review, no concerns were note .2 Procedures The licensee's procedures for processing, preparation, packaging and shipping radwaste materials were reviewed against criteria contained in 10 CFR 20.311, 10 CFR 71.5, 10 CFR 71.12 and Agreement State Burial Site license The following procedures were reviewed:

+0P-2511, "Radwaste Cask, Drum and Box Handling," Rev. 15;

+AP 0504, "Shipment and Receipt of Radioactive Material,"

Rev. 14;

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• 0P-2151, "Liquid Radwaste," Rev.12;

+0P-2153, "Solid Radwaste," Rev. 13; ,

• 0P-2208.3, "Cask Handling for TN-8L," Rev. 0; and

• 0P-2208.2 "Processing and Packaging of LPRM and SRM Drive Tubes," Rev. The eleven radwaste shipments were also reviewed against procedure requirements as applicable. Vermont Yankee Operations Procedures 2151, 2153 and 2511 are for routine radwaste operations involving liquid radwaste, centrifuge, solid waste and baling / compacting evolutions. Procedures VYOP-2208.2 and VYOP2208.3 were special procedures developed in conjunction with Shipment No. 87-9 of LPRM and SRM drive tubes sent to Hanford for burial. AP-0504 addresses receipt and shipment, e *fest preparation, 10 CFR 61 sampling and cther routine shipment equirement Within the scope of this review, no violations were note .3 Indoctrination and Training The licensee's indoctrination, training and retraining program was reviewed relative to commitments in the licensee's response to NRC IE Bulletin 79-19. Training records for six individuals with varying responsibilities for the eleven shipments of radioactive waste were reviewed. All of the records of these individuals indicated conformance to IE Bulletin 79-1 Within the scope of this review, no de lations were note .0 Quality Assurance (QA)/ Quality Control (QC)

Specific quality control requirements are mandated by 10 L7R 20.311 to assure compliance with 10 CFR 61.55 and 10 CFR 61.56. A Quality l Assurance program is required for transport packages in accordance with 10 CFR 71 Subpart H. A Commission approved QA program which satisfies the criteria of 10 CFR 50, Appendix B, Quality Assurance 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 l licensee uses the approved 10 CFR 50, Appendix 8 QA program of Yankee Atomic Electric Company (YAEC) to the packaging and transportation of radioactive material The inspector reviewed the licensee's packaging and transportation QA/QC

. activities implement ed by the license *'s site and corporate CA organizations. The inspector noted that the licensee used a "peer review" format for QC activities with surveillance and audit activities by the QA organization.

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5.1 Audits The licensee's program for audits of packaging and transportation dCtivities, radwaste preparation and CI;0sification, was reviewed against requirements in 10 CFR 50 Appendix B, Criterion XVIII,

"Audits" and Technical Specification 6.2, "Review and Audit". The licensee's performance in this area was determined by interviews of site QA personnel and review of Audit Report Number VY-87-09,

"Radwaste".

Within the Scope of this review, no violations were note .2 Surveillance / Inspection Activities The site QC and Receipt Inspection organizations provided overview functions on shipping and procurement activicies. Random surveillances of DOT or NRC requirements were performed on about half of the 1987 radwaste shipments and approximately SOP. of the 1988 radwaste shipments. The inspector reviewed the checklists used and noted that appropriate acceptance criteria and regulatory limits were provided in the checklist's attribute The inspector reviewed completed checklists for 1987 and 1988 and discussed resolution of any identified item Within the scope of this e eview, no violations were note .3 Waste Generator OC/ Process Control Programs under 10 CFR 20.311, the licensee is required to conduct a QC program to ensure compliance with 10 CFR 61.55 and 10 CFR 61.56

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.equirements for waste classification and waste characteristic The licensee's performance in this area was determined by review of Operations Procedures for preparing dewatered resins and compacted dry active waste, review of the procedure for manifest preparation for waste shipments, and discussions with personne Within the scope of this review, no violations were identifie .0 Radwaste Generator Requirements 6.1 The inspector reviewed each of the eleve,i shipments against each of the following requirements:

• Waste' Manifests under 10 CFR 20.311 (d)(4) and 10 CFR 20.311 (b) and (c);

• Waste Classification under 10 CFR 20.311 (d)(3) and 10 CFR 61.55;

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• Waste Form and Characterization under 10 CFR 20.311 (d)(3) and l 10 CFR 61.56; l

• Waste Shipment Labeling under 10 CFR 20.311(d)(2) and i 10 CFR 16.55; i

• Tracking of waste shipments under 10 CFR 20.311 (d), (e), (f) l and (h); arid

• Disposal site license requirements under 10 CFR 30.4 i

The bases for determing waste class through sampling, tN need to i re-establish scaling factors, and dose to curie calculation methods l were discussed with the Radwaste Coordinato l L

Within the scope of this review, no violations were note (

6.2 Procurenent and Selection of Packages I 1he licensee's selection of packages for the eleven shipments was reviewed relative to requirements in 49 CFR 173 and 10 CFR 71.12 and review of documents, procedures and shforing records. Purchase requisitions for steel liners, high integrity containers and NRC !

approved packaging was reviewe Dewatered resins are shipped in either steel liners or HIC's inside casks depending upon their specific activit Dry active wastes are shipped in LSA boxes !

designated as strong tight container Within the scope of this review, no violations were note .3 , Preparation of packages for Shipment The licensee's prepration of packages for shipment, pursuant to the requirements of 49 CFR 172 and 173 and 10 CFR 71.87 was reviewe The licensee's performance relative to these criteria was determined by interviews with the Radwaste Caordinator and review of procedures, shipping records and other record .4 Delivery of Packages to Carriers The licensee's delivery of packages to carriers was reytawed against criteria in:

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• 10 CFR 71.5(a)(1)(iii), "Placarding";

• 10 CFR 71.5 (a)(1)(vi), "Shipping Papers";

• 10 CFR 71.5(a)(2)(iv), "Public Highway";

+49 CFR 177; and

• Procedural requirement .

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The licensee's performance in this area was deteimined through review of shipping records and discussions with the Radwaste Coordinato Within the scope of this review, no violations were note .0 Exit Interview T.' inspector met with licensee representatives denoted in Section 1.0 at the conclusion of the inspection on September 30, 1987. The inspector summarized the scopt of the inspection anu the inspection findings. At no time during s, inspection were written material provided to the '

licensee by the inspecto l

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