IR 05000333/1986003

Safety Insp Rept 50-333/86-03 on 860128-31.No Noncompliance or Deviation Noted.Major Areas Inspected:Mgt Controls,Qa, Audits,Package Selection,Shipment of Radioactive Matls, Waste Classification & Previously Identified Items

ML20138B611
Person / Time
Site:	FitzPatrick
Issue date:	03/07/1986
From:	Clemons P, Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138B587	List: IR 05000333/1986003 ML20138B581
References
50-333-86-03, 50-333-86-3, NUDOCS 8603250116
Download: ML20138B611 (7)

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m U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-03

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Docket N License N DPR-59 Priority -

Category C Licensee: Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 Facility Name: James A. FitzPatrick Nuclear Power Plant

Inspection At: Scriba, New York Inspection Conducted: January 28-31, 1986

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Inspectors: [M h6 P. Clemons, Radiation Specialist 'date hM. Miller, h

'atifdn Specialist Y$kl-

'date Approved by: , .

R Lu- 4 W. M. Pasciak, Chief, ETfluents Radiation

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/ dite P"rotection Section, DRSS Inspection Summary: Inspection on January 28-31, 1986 (Report No. 50-333/86-03)

Areas Inspected: Routine, unannounced safety inspection of transportation activities including: management controls, quality assurance, audits, package selection, shipment of radioactive materials, waste classification, and status of previously identified item The inspection involved 47 inspector hours on-site by two regionally based inspector Results: The licensee was in compliance with NRC requirements examined during the inspectio G l

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OETAILS

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1.0 Persons Contacted 1.1 Licensee Personnel i *R. Converse, Resident Manager i * Fernandez, Superintendent of Power j *D. Lindsey, Operations Superintendent

! *E. Mulcahey, Radiological and Env. Services Superintendent

• R. Patch, Quality Assurance Superintendent

• R. Lacey, Asst. Operation & Superintendent and Acting Waste 1 Management General Supervisor I R. Ramstad, Warehouse Manager

J. Kerfien, Quality Control Supervisor 1 *L. Johnson, Quality Assurance Supervisor K. Szeluga, Radiation Protection Supervisor A. Young, Decontamination and Shipping Supervisor 1.2 Licensee Corporate Personnel

! J. Kelly, Manager Radiation Health and Chemistry

1.3 NRC Personnel

*A. Luptak, Resident Inspector

• Denotes attendance at exit interview Purpose The purpose of the routine safety inspection was to review the licensee's Radioactive Waste Management and Transportation Program. The following areas were reviewed:

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• Status of Previously Identified Items

Radioactive Waste Management Control

• Quality Assurance / Quality Control l

• Audits

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Waste Classification and Characterization

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• Package Selection

• Shipments of Radioactive Materials

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3 Status of Previously Identified Items 3.1 (Closed) Unresolved Item (333/85-24-03): Perform Safety Evaluation for change to Waste Solidification Processing System per 10 CFR 50.59. The inspector reviewed the licensee safety evaluation of the portable radioactive waste solidification system completed on December 27, 1985. The evaluation determined that the system change does not involve an un-reviewed safety question or involve a change in the Technical Specification .2 (Closed) Inspector Follow-up Item (333/85-24-0 ): Additional surveillanc'es of Radman and surveillances of the entire Process Con-trol Program. The licensee conducted a standard audit, Number 568, which included an independent verification of 10 CFR 61 waste clas-sification as compared to Radman. The licensee also audited a powdex resin shipment on November 23, 25, 27 and December 2, 1985. This audit examined the entire Process Control Program for a particular ,:

shipment including receipt and final cask inspection / surveys, valve and switch line ups, waste transfer operations and required chemical additions, and liquid content testin .0 Radioactive Waste Management Control The inspector examined the program's management controls with regard to organization structure, assignment of responsibilities and authorities, and management oversight. The inspector's assessment of this area was based on interviews with licensee personnel, examination of ongoing

, operations, and review of procedures and applicable record l The responsibility for the administration, technical direction and

oversight of radioactive waste shipment are the functions of the Waste Management General Supervisor (WMGS). The responsibility to supervise waste handling, packaging, and coordinating shipments are the functions of the Decontamination and Shipping Supervisor, who reports to the WMG Waste classification, review of radiation surveys, and shipping manifest preparation are the responsibilities of the Radiation Protection Supervisor, who reports outside the Operations Organization. These responsibilities were documented in the Position Descriptions, however the support role of the Radiation Protection Supervisor was not defined

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in the Operations administrative procedure The inspector noted that the WMGS, who was promoted to Assistant Operations Superintendent, had these dual positions since August, 198 .

Therefore, much of the management oversight was delegated to the Decontamination and Shipping Supervisor, who directly supervises waste processing and shipping activities performed by vendor staf The licensee stated that the WMGS would be filled within a few weeks, to

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increase oversight in this area.

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5.0 Quality Assurance / Quality Control The licensee's Quality Assurance / Quality Control Program was reviewed against the criteria cont,ained in 10 CFR 50, Appendix B, " Quality Assurance Criteria For Nuclear Power Plans and Fuel Reprocessing Plants" and 10 CFR 20.311(d)(3), " Transfer for disposal and manifests".

The licensee's performance relative to these criteria was determined by interviewing Quality Assurance / Quality Control personnel, Operations Personnel, the Warehouse Manager, and by reviewing procedures and other document Within the scope of this review, the following were identified:

As of July 1985, the licensee awarded a contract to a new vendor for the transportation and disposal of radioactive waste. The use of transport packages is an integral part of this contrac Under the licensee's quality assurance program, safety related material,

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parts and components are regarded as Category I items. Transport packages as not regarded as a Category I item by the licensee because they are not considered as safety related material, parts, or components. Transport packages are regarded as Category M items. According to the Quality As-surance Supervisor transport packages, a Category M item, must receive the very same screening as Category I items, i Procedure No. 10.1.5, " Control and Identification of Purchased Material and Services" states in Section 2.1, "This procedure shall apply, but not be limited to, safety related (Category I) material, parts and compon-ents,..."Section 7 of Procedure No. 10.1.5 requires that materials be received through the plant warehouse, and that these materials must be inspected by Quality Control upon receipt at the warehous The inspector determined that transport packages do not go to the warehouse upon receipt at the site, and neither are they inspected upon receipt by Quality Contro A licensee representative stated that the purchase order for the new ;

service was issued from the White Plains, N.Y. office and the purchase l order was apparently not identified as being safety related. The '

Warehouse Manager informed the inspector that he did not have a copy of this purchase order, therefore he had no knowledge of its existenc A quality assurance engineer informed the inspector that although the transport packages were not receipt inspected at the warehouse upon arrival by Quality Control, they were subsequently inspected by personnel of the new vendor who are on site performing other services for the licensee.

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The inspector stated that it is obvious that the licensee's receipt

, inspection system for transport packages had been circumvented, and he i

raised the question as to what other safety related items might have also bypassed the syste The Resident Manager stated that this issue would be reviewed to determine

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how such items could have circumvented the syste ,

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This item is considered as unresolved and will be reviewed during a sub-sequent inspection (333/86-03-01).

6.0 Audits j The adequacy and effectiveness of the licensee's audit program for trans-

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port packages were reviewed against the criteria contained in Criterion i XVIII of Appendix B, 10 CFR 50, and with respect to Technical Specification

! 6.16, " Process Control Program."

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

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review o'f audits and surveillances performed since 1984, and discussions with the Quality Assurance Supervisor and Quality Assurance Engineer.

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The qualifications of the auditor were reviewed relative to ANSI N45.2,

" Quality Assurance Program Requirements for Nuclear Facilities."

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

the following concerns were identified:

Audits required by Criterion XVIII of Appendix B, Part 50 for trans-port packages had not been adequately conducted during the period January, 1983 through September 1985. The focus of the audits was to determine the adequacy of procedure compliance, and that performance against the other designated 10 CFR 50, Appendix B criteria was mar-ginally evaluated. The licensee revised their QA Program by imple-menting QA Instruction-110, dated October 4, 1985. This instruction j required that the applicable criteria from 10 CFR 50, Appendix B be i

selected on a random basis throughout the yea ,

There was no QA/QC participation in dewatering operations or solidification during the preparation of packages for shipments in i

January 1985, processed and packaged by Chem-Nuclear.

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The procedures for radwaste solidification and implementing the process control program did not contain QA/QC hold points or any references to QA/QC participatio The licensee noted that-increased QA/QC involvement would be evident during radioactive waste solidification and shippin These concerns will be reviewed during a subsequent inspection (333/86-03-02).

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7.0 Waste Classification and Characterization

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The licensee's program for determining waste classification and character-ization were reviewed against the criteria of 10 CFR 61.55, " Waste Clas-sification" and 10 CFR 61.56, " Waste Characteristics."

The licensee's performance relative to these criteria was determined by j the following:

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discussions with the Radiation Protection Supervisor regarding waste j stream sampling program; l *

review of shipping manifests and sample shipping log for August 6, i 1984 through January 20, 1986;

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review of vendor report 05-701-1 for site specific waste correlation factors; and

review of selected program procedures including Process Control Program for NUSPC Radwaste Solidification System and Operating Pro-cedure for NUSPC System No. 8901.

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Within the scope of this review, no violations were identified. However, the inspector noted the licensee did not have a copy of the vendor Topical Report for Waste Form as suggested in an NRC Branch Technical Position Paper. The licensee stated a copy of the report would be onsite within the near futur '

With regard to waste stream sampling, the licensee took samples of all

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required waste streams every three months and updated the data base yearly, using the average resul The inspector noted that this methodology was acceptable provided no one quarterly sample exceeded the others by a factor of ten.

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8.0 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-e ments of 49 CFR Part 173.

For dry radioactive waste, the licensee used steel boxes or strong tight

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container Radioactive material shipments requiring the use of an NRC certified package (outer container) were made in vendor supplied

, containers. No Type B Casks had been used.

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Within the scope of this review, the following observations were made:

The licensee had not reviewed the Certificate of Conformance for Certificate of Compliance 9073 and Certificate of Compliance 9151 for NUS Cask Models14-170 and 10-135, respectively, to ensure that the statemer,t was curren *

Referenced drawings for Certificate of Compliance 9094 for Chem-Nu-clear Cask Model 14-195-H were not available. This cask had been used by the licensee prior to June,198 Except as noted above, copies of the Certificate of Compliance and required documents, procedures and drawings were available for all Type A Casks in use. These concerns and drawings will be reviewed during a subsequent inspection (333/86-03-03).

9.0 Shipment of Radioactive Materials The transportation of licensed material was reviewed against the criteria contained in 10 CFR 71, " Packaging and Transportation of Radioactive Ma-terial," 10 CFR 20.311(d)(3). " Transfer for disposal and manifests," and 10 CFR 61.55, " Waste Classification."

The licensee's performance relative to these criteria was determined by the following:

a discussion with the Decontamination and Shipping Supervisor;

review of shipping manifests and related documents for 1984, 1985 and 1986; and a

review of selected program procedures including the following:

• F-0P-48A, Revision 10, " Documentation of Radwaste Shipments"

• F-0P-488, Revision 10, " Waste Packaging and Handling"

• F-0P-48E, Revision 0, " Radioactive Material Segregation"

• F-OP-48C-9, Revision 1, " Handling Procedure for the NUS14-170 Cask"

• F-0P-48C-10, Revision 3, " Handling Procedure for the NUS10-135 Cask"

• AP1.10, Revision 0, " Process Control Program Within the scope of this review, no violations were identifie . Exit Meeting The inspector met with the licensee representatives (denoted in paragraph 1.1) at the conclusion of the inspection on January 31, 1986. The inspec-tor summarized the scope of the inspection and finding !

l At no time during this inspection was written material provided to the i licensee by the inspecto l

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