IR 05000309/1981018
| ML20041B843 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/08/1982 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20041B837 | List: |
| References | |
| 50-309-81-18, NUDOCS 8202250254 | |
| Download: ML20041B843 (10) | |
Text
..
.
-.
.
.
-
,
.
.
,
.
.
'
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
,
Report No. 50-309/81-18 i
Docket No. 50-309 License No. DPR-36 Priority Category C
Licensee: Maine Yankee Atomic Power Company
!
1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Maine Yankee Nuclear Generating Station j
Inspection at: Wiscasset, Maine Inspection conducted: July 27 30,1981 Inspectors:
[
/j w[z]
$/
h-K+ -
Plumlee, Rad'iaTion' Specialist
' date signed Approved y:s !
G?
N asm -
f2-P. %). Knapp, Chief, Facility Radiological
/ pate signed Protection Section, Technical Inspection Branch Inspection Summary:
Inspection on July 27-30, 1981 (Report No. 50-309/81-18)
Areas Inspected:
Routine unannounced inspection by a regional based inspe ctor of the transportation program maintained to ensure safe receipt, packaging,
,
,
delivery to a carrier, and transport of licensed radioactive materials, j
including:
organization; quality assurance; procedures; training; audits; j
selection of packaging; preparation of packages for shipment; delivery of completed packages to carriers; receipt of packages; incident reporting;
'
!
examination of packages; and shipping records. This inspection involved 26
inspector-hours onsite by one NRC regional based inspector.
Results:
No items of noncompliance were identified.
i
'
I 8202250254 820211
-
PDR ADOCK 05000309 G
[
.
.
DETAILS 1.
Persons Contacted
- G.Cochrane, Radiological Controls Supervisor
- D. Ivins, YAEC Operational Quality Assurance (0QA) Coordinator
- A. Jordan, 0QA Coordinator
- G. Joseph, OQA Engineer
- R. Lawton, Director, 0QA
- D. Sturniolo, Assistant to the Plant Manager
- E. Wood, Plant Manager
- Denotes presence during the exit interview on July 30, 1981.
2.
Review of the Management Controls of the Transportation Program a.
Organization, Responsibilities and Authorities The inspector reviewed the documentation listed below to verify that the organization, responsibilities, and authorities of the personnel involved in the packaging, preparation for transport, and transport of radioactive materials were designated in writing:
Technical Specifications Job Descriptions Procedures (paragraph 2.c)
Quality Assurance (QA) Program Interviews with seven individuals did not identify any discrepancies between the above documentation and actual practices. The following on-site assignments were in effect.
Operations Operation of the radwaste system Resin dewatering Liquid waste solidification Health Physics Records of transfers and shipments Required copies of documents including 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
r
.
.
Final clearance for each vthicle to transport radioactive materials offr.ite Vehicle surveys and placa ds Container acceptability, labels, and surveys Receiving surveys for radioactive material packages and shipments Chemistry Samples and analyses
.
Plant Services 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 radioactive waste for storage or shipment Maintenance Loading, unloading or moving of casks, etc.,
requiring hoists or cranes.
Repairs and mechanical adjustments to equipment Quality Assurance Independent audits of the above activities Quality Assurance / Quality Control of contracted supplies and services QA/QC of purchased or leased equipment On site QA/QC of processes, equipment and materials Vehicle inspection for road worthiness The inspector discussed with the licensee. representative the recommen-dation to implement a radwaste reduction program, as presented in a letter from D. G. Eisenhut, Acting Director, Division of Operating Reactors, " Low Level Radioactive Waste Disposal," January 29, 1980, addressed to all power reactor licensees.
The inspector determined that the licensee had briefed plant personnel on the economy of l
radwaste reduction and had followed the two examples stated in the i
above reference, e.g., segregration of nonradwaste from radwaste, and the use of a compactor to reduce the volume of compactible dry radioactive waste.
No items of noncompliance were identified.
b.
Training on DOT and NRC Requirements
!
In letters dated September 24, 1979, and March 7, 1980, the licensee i
committed to provide training and periodic retraining covering DOT
'
and NRC requirements, waste burial license requirements, and applicable plant procedure requirements for all employees involved in transfer,
,
packaging, and transport of radioactive material.
!
!
.. _ - -
- _.-
,r,
_, _ -,
,
__
...,
...
...
..
.
_
.,.. _.. _ _
. _ _,_
,_ _ _
_-
m
.
.
.
The inspector reviewed the training procedures, and tlio training records of 20 individuals, 10 from health physics and 2 from each of the other organizational groups listed above in paragraph 2.a., to determine their training. The licensee maintained training procedures and records that implemented the commitments specified in the letters described above.
An interview disclosed that the Radiological Controls Supervisor and his assistant had received additional training during both 1980 and 1981 which was not documented in the above records. As an example, both individuals attended a training seminar on the above topics conducted by Chem-Nuclear, Inc., at Barnwell, South Carolina (January and March, 1981). This training appeared commensurate with their level of responsibility. The licensee committed to document this training and place copies in their personnel folders.
Review of the QA/QC personnel training was by interviews, because there were no training procedures, and no records in their folders, indicating their training on the above topics. The individuals interviewed stated they had attended training provided for the HP technicians, and had read the applicable regulations on their own initiative. The inspector verified their attendanca at the HP training by review of the attendance sheets. The inspector concluded that the training provided for the QA/QC personnel was sufficient to
permit them to audit the licensee's adherence to the procedures used
in radwaste transportation.
t c.
Procedures for the Receipt, Packaging and Transport of Radioactive Materials The inspector reviewed copies of the directives, procedures, and instructions listed below; observed the adherence to these documents, and reviewed several completed shipping records (see paragraph 8)
to verify compliance with the DOT and NRC transportation regulations:
Document Revision Date Designation Number Issued Abbreviated Title 9.1.14
5/80 Receipt of Radioactive Material 9.1.15
1/81 Shipment of Radioactive Material 9.1.17
2/80 Processing Radioactive Solid Waste
,
9.1.18
1/81 Receipt and Handling of New Fuel 9.237
3/80 Health Physics Departmental Training Program 1-111-1
9/79 Auxiliary Operator Training (Waste solidification procedure 1-18-4)
!
.
. -. - - -.
_
, _ _ - -, _
.
._-. - - - -, - - - - -,
-, _ -,, _
--
- -~,_,
_
.
.
.
Document Revision Date Designation Number Issued Abbreviated Title 0QA 79-172/5.3.8 NA 5/79 Memo-QA Requirements for 10 CFR 71 Radioactive Shipments Y0QAP-1-A
4/81 Other Items Requiring Quality Appendix Assurance Criteria V 0QA-X-1
1/81 Quality Assurance Inspections No items of noncompliance with the above procedures were identified.
d.
Audits of Transportation Activities The licensee's September 24, 1979 letter referenced above committed.
to the following:
"A management controlled audit of radioactive waste transfer, packaging and transport activities is provided by the Yankee Atomic Electric Co., Yankee Nuclear Services Division,"
(YAEC/YNSD).
The review of one of these audit reports was documented in Report No. 50-309/81-03 under Item No. 79-19-02.
In addition to the above, the YAEC/YNSD audited three vendors of shipping containers (audit dates April 2, August 24-25, and September 1-3,1981).
These reports were discussed during a telephone contact with D. B. Pike, YAEC QA Director, on September 9,1981.
The licensee stated that, in addition to the above audit program, an outside organization, Nevada Testing Service, was scheduled to audit the transportation program during the summer of 1981.
Review of records (see paragraph 8) verified that the on-site QA/QC activities were being conducted in accordance with the procedures.
No items of noncompliance were identified. As further described in paragraph 2.e, Maine Yankee was terminating the YAEC/YNSD respon-sibilities.
e.
Review of the Quality Assurance Program, Approved Pursuant to 10 CFR 71.51(a)
The inspector determined that the Maine Yankee Atomic Power Company (MYAPC) has approval to transport radioactive materials in accordance with the Yankee Operational Quality Assurance Program 1-A (Y00AP-1-A),
.:
based on a review of the correspondence listed below. The original approval was obtained by Yankee Atomic Electric Company (YAEC) and applied to MYAPC and two other reactor licensees. YAEC and Yankee
.
.
_
. _. _. _ _
_ _ _ __
_
_
.
-_
__
._
_
. _..
.
_.
__ _
_
,
,
.
6
,
Nuclear Services Division have the corporate level QA/QC respon-sibilities under YOQAP-1-A. However, Maine Yankee was withdrawing from this arrangement.
Recently MYAPC applied to NRC's Division of Licensing (DOL) pursuant to 10 CFR 50.34 for approval of a Maine Yankee Operational Quality
Assurance Program (MY0QAP) that did not include the other two reactor licensees, YAEC, or YNSD. Approval was received, and MYOQAP was implemented on September 1, 1981.
,
Review of the documentation of these matters revealed that MYOQAP had not been submitted to the Director, Office of Nuclear Material Safety and Safeguards (NMSS) for approval pursuant to 10 CFR 71.51(a),
and until NMSS approval was obtained it would be necessary to continue to comply with YOQAP-1-A for radioactive materials transportation.
,
l
The MYQA Director informed the inspector by telephone on September 18, 1981, that the application has been made for NMSS approval of the MYOQAP program for transportation, and no shipments of greater than Type A quantities of radioactive materials would be made until NMSS approval was obtained.
The inspector reviewed the documents listed below, which were applicable
,
to the Quality Assurance / Quality Control Program.
i Document Identification Date Title (or Subject)
Originator
YAEC Letter 6/5/78 10 CFR Part 71 L. H. Heider
Appendix E NMSS Letter 4/10/79 (YAEC's Application C. E. MacDonald for QA program approval)
<
YAEC Letter 4/24/79 10 CFR Part 71, L. H. Heider Establishment...
YAEC Memorandum 5/18/79 QA Requirements for D. B. Pike 10 CFR 71 Radioactive Shipments NRC:00L Letter 4/30/81 (Acceptability of R. A. Clark MYOQAP)
-
MY Letter 7/23/81 (Implementation of J. H. Garrity MYOQAP)
MY Letter 9/81 (Letter requesting R. Lawton NMSS approval of QA)
,
The current quality assurance program applicable to transportation will be inspected on a subsequent inspection (81-18-01).
,
!
i
-
.-
-.. -. _
. - -. _.,
,.
.
-
. -
-.
, _ _
_-. _,
. - --
..
- --~
--.
.
_
-- _
.
.
,
No items of noncompliance were identified.
3.
Selection, Procurement and Rause of Packaging The licensee controlled the procurement of Type A and Type B packaging under the existing QA plan. A qualified vendor list was also maintained.
Review of the vendors' literature, manuals, and contractual agreements verified the inclusion of assurance that the vendors complied with DOT and NRC regulations.
Examination of the following empty containers onsite did not identify any problems:
Four Chem-Nuclear (Type 21-300 plastic) high integrity containers, serial nos. 29514-28, -37, -44, -52 Two Chem-Nuclear (Type L21-300 BTFE steel) containers, serial nos.
BW-25722-31 and BW-25294 (March 15, 1981 and August 23,1980)
Four 55 gallon drums, DOT Specification 17H STC (February,1981)
One laundry drum, DOT Specification 6-J (used)
Twelve plywood boxes, 4 ft. x 4 ft. x 8 ft. (new, some empty, some partially filled, and some filled)
Ten new fuel shipping containers No Type B or large quantity packages were being processed during this inspection or the previous onsite observation periods (see Report No.
50-309/81-11).
The inspector observed the filling, closing, and loading for shipment of several radwaste packages. The inspector selected one package (Type A quantity) to be opened for ins,ection.
The inspector reviewed copies of the Certificates of Compliance, user's registrations, QA/0C records, and shippirig records (see paragraph 8).
These documents did not identify any noncomplying packaging.
The inspector noted that the licensee procedures encompassed the reuse of those radioactive materials shipping containers and packaging that were identified onsite or in the shipping records.
These were:
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
)
-
_ - - _ _ -
.
.
-
-..
_
_
_
_
_m
.
.
8 Laundry drums used to transport protective clothing to the laundry, round trip Containers for tools and equipment used in the controlled area i
The licensee representative stated that:
No foreign made packaging was used; No packages were used that had an outside dimension as small as 4 inches; No special form radioactive material shipments were made; and No plutonium was shipped during 1980 or 1981 to date.
The inspector noted that the HP technician on the job during the loading of vehicles was required to check each container or package for loose surface contamination, radiation level, closure, labeling, and general condition.
The inspector observed the preparation of two exclusive use vehicles 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.
4.
Control of the Preparation of Packages for Shipment, and Delivery to Carriers The Radiological Controls Supervisor or his. assistant 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 i
!
Package closure and seals 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 verified that the procedures specified proper labeling, j
marking, and placarding; and that the licensee adhered to the procedures l
during the preparation and release of two shipments from the site.
- -. - -
,
,
. -
.,,
.
,...
-
.
.
.
--
._
_ - -
.
.
.
i
4
!
5.
Description of Packaging, Contents, and Classification
The inspector verified that the licensee procedures included the criteria and action levels necessary to comply with the regulatory requirements in regard to 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 (see paragraph 2.c).
Review of shipping records verified the licensee's adherence to these instructions (see paragraph 8).
An examination of 12 packages loaded on transports for shipment did not identify any items of noncompliance.
6.
Control of Preparation of the Transport Vehicle for Departure The inspector observed that, in accordance with the procedures, the Radiological Controls Supervisor controlled the scheduling, loading and departure of transport vehicles carrying radioactive materials; verified
<
the container closure and tiedown to the transport vehicle; and signed the required certification.
A contractor's representative was present and stated that he also independently verified the status of the containers and contracted vehicles before j
departure.
i 7.
Notifications to Consignees and, As Necessary, 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.
8.
Review of Shipping Records The inspector reviewed the following material receipt and shipping records i
and associated file copies to verify that the licensee adhered to procedures and complied with regulatory requirements concerning:
Authorization to depart the site Surveys, radiation levels and contamination i
QA/QC inspection and audit of each container of greater than a Type A quantity of radioactive materials
_
- _ - - __
__._ -, -.
__
..
.
_
_
-
.-
-
- -.. -. -
_...
_
_.. -.- - _ -- -.
.
.
';
'j0 i
Maintenance
,
Procedures for package use Filling and loading of packages
Proper contents of packages Package closure and binding
'
}
Mounting and tiedown of containers on vehicles Package identification and marking
Package certification Special instructions for package use
_ Shipper's certifications and criteria for burial site acceptance Shipping instructions Identification of transferee
,
i Destination and routing of shipment
!
Shipment dates.
Incident reports The inspector selected and reviewed samples of the licensee radioactive
.
materials receiving and shipping records for 1981 (shipments 81-1 to 81-40; to 81-L-9; and to 81-W-5).
Review of records of five Type A and five Type B shipments did not identify any problems.
9.
' Exit Interview The inspector met with the licensee representatives, denoted in paragraph 1,.on July 30, 1981, to review the inspection findings.
4 i
m.-
-~
. - - -
-m,
-,-.-en
-
,
e------,
-,e---e,-----
.
-
,
-,r--,
, > -,--,
- --
c--
,e-
~,-
-~-
v,- - -
~