Information Notice 1987-07, Quality Control of Onsite Dewatering/Solidification Operations by Outside Contractors

Quality Control of Onsite Dewatering/Solidification Operations by Outside Contractors

ML031130531
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	02/03/1987
From:	Jordan E NRC/IE
To:
References
IN-87-007, NUDOCS 8701300079
Download: ML031130531 (5)

SSINS No.: 6835 IN 87-07 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D. C. 20555 February 3, 1987 IE INFORMATION NOTICE NO: 87-07: QUALITY CONTROL OF ONSITE DEWATERING/

SOLIDIFICATION OPERATIONS BY OUTSIDE

CONTRACTORS

Addressees

All nuclear power reactor facilities holding an operating license (OL) or

construction permit (CP).

Purpose

This notice is intended to remind licensees of their responsibility to ensure

that appropriate quality control measures are carried out during the operation

performed by outside contractors of transportable dewatering and/or solidifica- tion radwaste processing equipment at the site of a licensed facility. It is

suggested that recipients review the information for applicability to their

facilities. No written response is required.

Related Documents:

NRC IE Information Notice No, 79-09, "Spill of Radioactively Contaminated

Resin," March 30, 1979. This notice reminded licensees of their responsibility

to review the adequacy of the equipment and procedures used by such outside

contractors.

NRC IE Circular 80-18, U10 CFR 50.59 Safety Evaluation for Changes to Radio- active Waste Treatment Systems," August 22, 1980. This circular pointed out

that in some instances, licensees have failed to perform adequate safety

evaluations to support changes to solidification/dewatering systems operated by

an outside contractor at a licensee's facility, so as to determine that there

are no unresolved safety issues.

Background:

The functions performed by mobile transportable radwaste processing equipment

for solidification or dewatering (e.g., usually skid mounted or truck mounted)

are very often performed by outside contractor personnel. Such operations

fall within the scope of the operating reactor's license issued pursuant to

10 CFR 50. Therefore, regardless of the specific method of processing the

waste or the contractor involved, the licensee is responsible for ensuring

that all such activities on his site are carried out in a manner consistent

with the facility operating license and applicable technical specifications, process control program and regulations, in a manner that provides adequate

protection from the health, safety, and environmental standpoints.

IN 87-07 February 3, 1987 A very important and somewhat recent regulatory requirement relating to such

operations is found in 10 CFR 20.311(d)(3), which requires that a licensee

shall " ....conduct a quality control program to assure compliance with

§§61.55 and 61.56 of this chapter; the program must include management

evaluation of audits."

Description of Circumstances

Several recent NRC inspections have revealed inadequacies In quality control

programs during such operations. A typical result of these inadequacies is

the failure to reduce the water content of solidified wastes or dewatered resins

to the applicable limits; for example, either 0.5% by volume of the stable waste

form or 1% by volume of the waste when placed in a disposal container, a "High

Integrity Container" which is designed to ensure stability. This has resulted

in enforcement actions and/or civil penalties against the shipper/licensee by

the burial site state licensing authority. In some instances, it has been

observed that no quality control program is in place by either the contractor

or the licensee. Typically, the contractor might perform the solidification/

dewatering without any holdpoints or quality control check points by either

the licensee or the contractor, especially a control check that is Independent

of the operator of the waste processing equipment. It has also been found

that in some cases, quality assurance audits have neither been performed nor

have the results of such audits, when performed by contractor personnel, been

reviewed by licensee management.

Discussion:

The operations conducted at a licensee facility by an outside vendor are usually

addressed in the licensee's process control program, which is an incorporated

requirement of the applicable Technical Specification. It is incumbent on the

licensee to exercise oversight and control of all aspects of the contractor's

operation. This includes review of sample results, test solidification results, product verifications, and quality control audits. Licensee controls must be ade- quate to ensure compliance with the requirements of 10 CFR 20.311 and 10 CFR 61.56.

It is expected that licensees will review the information provided for applica- bility, if appropriate, to their waste management programs. However, suggestions

contained in this notice do not constitute NRC requirements; therefore, no

specific action or written response is required.

IN 87- January , 1987 If you have questions regarding this matter, please contact the Regional

Administrator of the appropriate NRC regional office or this office.

Edward L. Jordan, Director

Division of Emergency Preparedness

and Engineering Response

Office of Inspection and Enforcement

A. W. Grella, IE

(301) 492-7746 Attachments:

List of Recently Issued IE Information Notices

(* See previous concurrences

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Attachment 1 IN 87-07 February 3, 1987 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

87-06 Loss of Suction to Low- 1/30/87 All power reactor

Pressure Service Water facilities holding

System Pumps Resulting From an OL or CP

Loss of Siphon

87-05 Miswiring in a Westinghouse 2/2/87 All Westinghouse

Rod Control System power reactor

facilities holding

an OL or CP

87-04 Diesel Generator Fails 1/16/87 All power reactor

Test Because of Degraded facilities holding

Fuel an OL or CP

87-03 Segregation of Hazardous 1/15/87 All NRC licensees

87-02 Inadequate Seismic Quali- 1/15/87 All power reactor

fication of Diaphragm facilities holding

Valves by Mathematical an OL or CP

Modeling and Analysis

87-01 RHR Valve Misalignment 1/6/87 All PWR facilities

Causes Degradation of holding an OL or CP

ECCS in PWRs86-110 Anomalous Behavior of 12/31/86 All BWR facilities

Recirculation Loop Flow holding an OL or CP

in Jet Pump BWR Plants86-109 Diaphragm Failure In Scram 12/29/86 All BWR facilities

Outlet Valve Causing Rod holding an OL or CP

Insertion

86-108 Degradation Of Reactor 12/29/86 All PWR facilities

Coolant System Pressure holding an OL or CP

Boundary Resulting From

Boric Acid Corrosion

86-107 Entry Into PWR Cavity With 12/29/86 All power reactor

Retractable Incore Detector facilities holding

Thimbles Withdrawn an OL or CP

OL = Operating License

CP = Construction Permit

IN 86- December , 1986 If you have questions regarding this matter, please contact the Regional

Administrator of the appropriate NRC regional office or this office.

Edward L. Jordan, Director

Division of Emergency Preparedness

and Engineering Response

Office of Inspection and Enforcement

A. W. Grella, IE

(301) 492-7746 Attachments:

1. Applicability of Licensing and Regulatory Requirements

to the Mobile Radioactive Waste Service Industry

2. List of Recently Issued IE Information Notices

(* See previous concurrence)

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