ML17053C926
| ML17053C926 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/17/1981 |
| From: | Baer R, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C925 | List: |
| References | |
| 50-220-81-10, IEB-79-19, NUDOCS 8111130448 | |
| Download: ML17053C926 (18) | |
See also: IR 05000220/1981010
Text
U.S.
NUCLEAR REGULATORY COMMISSION
OFFICE
OF INSPECTION AND ENFORCEMENT
Region I
Report
No
-.:50-.220/81-10
Docket No.
50-220
License
No.
Licensee:
Priority
Category
300 Erie Boulevard West
Syracuse,
13202
Facility Name:
Nine Mile Point, Unit 1 (NMP-1)
Inspection at:
Oswego,
April 28 - May 1,
1981
Inspectio
-end
Inspectors:
R. Baer, Radiation Specialis
I- I z-'l
date signed
date signed
Approved by: P..
Knapp, Chief,
Fa lity Radiological
Protection Section,
DETI
date signed
.
g- l7- 8't
date signed
Ins ection
Summar
Inspection
on
A ril 28
Ma
1,
1981
Re ort No. 50-220 81-10
dd
d
d
by
d
bb
dd
d
on transportation activities and radioactive waste
management
programs including:
management
controls; selection of packages;
preparation of packages for shipment;
delivery of completed
packages
to carrier; receipt of packages;
incident reporting;
indoctrination and training program
audit program;
and recordkeeping.
The
inspection involved 28 inspector-hours
onsite
by one regional
based
inspector.
Results:
Op the nine areas
inspected,
no items of noncompliance
were identified
>n seven areas.
Two items of noncompliance, were identified in two areas
- receipt
of packages
(paragraph
6) and audit program
(paragraph
9).
Region I Form 12
( '" Apr"
)
'DR ADOCK 05000220
Si 1 ii3044B 8i i022
8
'DR
IL
II
'I
I,
I
I
I'
DETAILS
Persons
Contacted
- Hr. J.
Mr. Ll.
- Mr. J.
Mr. C.
- Hr. E.
- Hr. G.
Mr. J.
- Hr. T.
- Hr. T.
C. Aldrich, Trai'ning Superintendent
- Nuclear
Bryant, Manager, Ouality Control
N. Duell, Chemi'stry
and Radiation Protection Supervisor
A. Gerber,
Radwaste
Operations
Coordinator
H. Leach, Superintendent,
Radioche'mistry
and Radiation Protection
R. Leskin, Acting Supervisor
OC Operations
Pavel, Assistant Supervisor Training - Nuclear
T. Perkins,
General
Superintendent
H.
Roman, Station Superintendent
Other Personnel
Mr. S.
Hudson,
Reactor Inspector
(Resident),
The inspector also interviewed several
other licensee
employees
and
contractor personnel
including members of the Radiation Protection
and
Operati'ons
Departments.
- denotes
those present at the exit, interview on Hay 1, 1981.
Mana ement Controls
The inspector
reviewed the management
control of the radioactive waste
program.
The licensee
has not designated, in writing, by either
an admini-
strative procedure
or incorporation in the appropriate
job description,
those
persons
responsi'ble
for the overall radioactive waste
management
program.
In response
dated
August 10, 1979,
the
licensee stated,
"The Radwaste
Operations
Coordinator
and the Radiochemistry
and Radiation Protecti'on Supervisor of Nine Mile Point Unit
1 are responsible
for the safe transfer,
packaging
and transport of low level radioactive
material.
The Plant Superintendent
or his designee
must approve
each
radioactive
shi'pment
by si'gni'ng the shipping papers."
A licensee's
repre-
sentati,ve
stated that
a management
statement
delegating
those
persons
responsible for the overall radwaste
program will be written by September
15, 1981.
The Radwaste
Operati'ons
Coordinator reports
through the Supervisor,
Operations
to the Station Superintendent,
who reports
to, the General
Superintendent,
Nuclear Generati'on.
The Supervisor,
Chemistry and Radiation Protection,
'"reports to the Superintendent,
Radiochemistry
and Radiation Protection,
who then reports- to the
General
Superintendent,
Nuclear
Generation.
The
two individuals who have the responsiblity for the overall radioactive
waste
management
program work closely together for all radioactive
waste
shi'pments.
P
The licensee
has
undertaken
a re-organization of the radwaste
operations
program below the positi'on of Radwaste
Operations
Coordinator.
Presently,
the licensee
uses
auxi,li'ary operators
from the Operations
Department
on
an as-needed
basis.
Under the re-.organization,
which has received
manage-
ment approval,
dedicated auxiliary operators will perform radwaste
functions.
No items of noncompliance
were identified in this area.
3.
Selection of Packa
es
The licensee's
program for selection of packages
was reviewed against
the
requi'rements
of 1Q .CFR Parts
71. 12 and
54 and the
DOT requirements
of 49
CFR
Part 173.
For dry radioactive waste,
the licensee
uses
wooden
boxes
as strong tight
containers
or steel
drums manufactured
in accordance
with DOT Specification
17H.
Shipments of evaporator
bottoms
and spent demineralizer resins
are
made in steel
containers- manufactured for, and obtained from, the supplier
of the
DOT Specification
7A container
(outer package},
Copies of the, Certificate of Compliance,
supporting safety analysis,
and
cask handling procedures
were available for all Type
A and Type
B casks
in use.
All shipments of radioactive material
were
made
as full load shipments
in
a transport vehicle consigned
as exclusive
(sole } use only.
No items of noncompliance
were identified in this area.
I
4.
Pre aration of Packa
es for Shi ment
The licensee's
program for preparation of radioactive material for shipment
was reviewed against
the requi:rements of 10 CFR Parts 71.11,
21, 24,
53 and
54 and the following:
Regulatory
Guide 7. 1
Administrative Guide for Packaging
and Trans-
porting Radi;oactive Hateri'al
Regulatory
Guide 7.4 - Leakage
Tests
on Packages
for Shipment of
Radioactive Haterials-
ANSI N14. 10. 1. - Administrative Guide for Packaging
and Transporting
Radioactive Material
ANSI N14.5 - Leakage Tests
on Packages
for Shipment of Radioactive
Haterials
49
CFR Parts
172 and
173
Transportation
1
Activities in the preparation of radioactive material for shipment
are
governed
by the following procedures'..
NI-WHP-l, Required
documents
concerning
packaging
and shipping of radio-
active waste,
Revision 0, dated 6/24/80
NI-WHP-2, Initial paperwork for a radioactive waste shipment,
Revision 0,
dated I/30/81
NI-WHP-3, Cask handling procedure,
Revision 0, dated 6/24/80
NI-WHP-4, Cask loading procedure,
Revision 0, dated 2/6/81
NI-WHP-5, Cask shipment preparation
procedure,
Revision 0, dated
1/26/81
NI-WHP-6, Van handling procedure,
Revision 0, dated
1/26/81
NI-WHP-7, Van loading procedure,
Revision 0, dated I/26/81
NI-WHP-8, Van shipment preparation
procedure,
Revision 0, dated 4/9/81
NI-WHP-9, Solidification procedure,
Revision 0, dated 4/6/81
NI-WHP-ll, Process
control procedure,
Revision 0, dated 4/6/81
NI-WHP-12, Solid dry waste collection
and compaction,
Revision 0, dated
4/2/81
The inspector
examined
these
procedures
for consistency with regulatory
requirements
and to determine
whether
they covered all aspects
of the
work being carried out.
Records
and work in progress
were observed
to
verify adherence
to the procedural
requirements.
The licensee
used
a check-off list to assure
that procedures
were followed
and that the packages
were properly prepared
in accordance
with DOT,
state
and burial site requirements.
The completed check-off list was
retained with the radioactive material
shipping record.
No items of noncompliance
were identified in this area.
5.
Deliver
of Com leted
Packa
es to Carrier
The licensee's
program for, delivery of completed
packages
to a carrier
for transport
was reviewed against
the requirements
of 10 CFR 71.55
and
49
CFR Parts
100 to 199.
Activiti'es- for delivery of completed
packages
to a carrier were governed
by the following procedures:
NI-WHP-l, Required. documents
concerning
packaging
and shipping of radio-
active waste,
Revision 0, dated 6/24/80
NI-MHP-2, Initial paperwork for a radioactive waste shipment,
Revision 0,
dated 1/30/81.
NI-WHP-5, Cask shipment preparation
procedure,
Revision 0, dated
1/26/81
NI-WHP-8, Van shipment preparation
procedure,
Revision 0, dated 4/9/81
The inspector
examined
these
procedures
for consistency with regulatory
requirements
and to determine
whether they covered all aspects
of the
work being performed.
Records
to verify adherence
to procedural
require-
ments were also reviewed.
No items of noncompliance
were identified in this area.
Recei t of Packa
es
10 CfR 20.205(d) states;
"Each licensee
shall establish
and maintain
procedures
for safely opening
packages
in which licensed material is
received,
and shall
assure
that such procedures,
are followed and that
due
consideration
is given to special
instructions for the type of package
being opened."
20.205(b)(1) states:
"Each licensee,
upon receipt of a
package of radioactive material shall monitor the external
surfaces
of
the package for radioactive
contamination
caused
by leakage of the radio-
active contents,....
The monitoring shall
be performed
as
soon
as prac-
ticable after receipt,
but no later than three hours after the package
is
received during the licensee's
normal working hours,
or eighteen
hours if
received after normal working hours.
(2) If removable radioactive
contamina-
tion in excess of...is found on the external
surfaces
of this package,
the licensee
shall
immediately notify the final delivering carrier and,...
the appropriate
Nuclear. Regulatory
Commission
Inspection
and Enforcement
Regional Office...."
The licensee
did not establish
and maintain procedures
for safely opening
packages
containing radioacti;ve materials.
Procedures
existed which
providedguidance
on radiation
and contamination limits but did not
specifically address
the steps
necessary
for the safe opening of packages,
the survey time requirements-, .nor the requirements
for notification of
the delivering carrier and
NRC regional office when limits were exceeded.
The inspector
informed licensee
representatives
that the failure to
establish
and maintain
such procedures
for the receipt,
surveying
and
safe opening of packages
containing radioactive material constituted
noncompli'ance with 10 CFR 20. 205.
The licensee
representative
acknowledged
this deficiency and immediately issued
a memorandum to security, operations
apd health physics
personnel
advising
them of these
requirements.
The
licensee
representative
stated that
an approved
procedure
would be available
by June
1,
1981
(81-10-01).
Incident
Re ortin
The licensee
used contract carriers for the transportation of all radio-
active materials.
These carriers
had
a written list of personnel
and
agencies
to contact for any incident which may occur during the course of
transporting radioactive materials.
%he plan 'stipulated that the contract
carriers'ispatcher
would notify the licensee of all incidents
and unanti-
cipated delays encountered
during transport activity.
Packages
offered for transport
were inspected prior to loading
on the
transport vehicle
and during unloading.
There
have
been
no instances
where the effectiveness
of the packages
were substantially
reduced during
use.
No items of noncompliance
were identified in this area.
Indoctrination
and Trainin
Pro ram
The licensee's
indoctrination
and training program
as it pertained
to the
packaging of low level radioactive waste for transport
and burial
was
examined against
the requirements
and the licensee's
response
to this bulletin.
The inspector
reviewed documentation of the training conducted
since
January
1980 for personnel
involved in the transfer,
packaging
and transport
of radioactive material.
Training courses
of three
weeks duration
were provided to all radiation
protection technicians
during the period of December
1980 through February
1981.
Included in the course
was
a seven-hour
segment
devoted to
NRC 10 CFR Part 20 and -DOT regulations
pertaining
to the shipment of radioactive
material.
Operator training is recorded
on the individual's operations
training
manual
which covers
both. non-licensed
operator training and license
candidate training requirements.
The inspector
reviewed the operations training manual of five auxiliary
operators
"B", including the System/Equipment
Operations
Record
and the
Reading Assignment
Record.
Of the five records
reviewed,
two of the
individuals
had
no entries
in either the System/Equipment
Operations
Record sheet or the Reading
Assignment
Record.
A third individual
had
no
entry in the Reading Assignment
Record,
but had successfully
completed
the System/
Equipment, Operations
assignments.
No training had
been
received
by any of the five persons
on the Naste Handling Procedures.
In
discussion with a licensee's
representative it was determined that the
training, group performs
a quarterly audit of the training completed
by
the operations
department
but there
was
no management
enforcement
to
ensure
completion of the training.
The inspector
expressed
concern that
there
was
no formal on-the-job training or guidance instructions to
assure that. systems
were fully described
and correctly operated
during the
performance'testing
phase of training.
The licensee's
representative
stated
they would review the training program
and provide more management
direction.
The inspector indicated that the training program
and documentation will
be reviewed at
a subsequent
inspection
(81-10-02}.
9.
A~Ah
9
The licensee's
audit function for the low-level radioactive waste transfer,
packaging
and transport activities was examined against
the requirements
of 10 CFR 71
and
and the following generally accepted
guidance:
Regulatory
Guide
1. 33 - equality Assurance
Program
Requirements
ANSI N18.7-1976 - Administrative Controls
and Ouality Assurance
for
the Operational
Phase of Nuclear
Power Plants
Activities of the station quality assurance
program were governed
by the
following procedure:
gAP
1.21
Performance,
Reporting
and Followup of Surveillance
Activities for Operations.
The inspector
reviewed all Radioactive flaste
Management Ouality Audits
performed since January
1979.
The following audits
had
been
conducted:
1979
79-026A
Pickup and transport of packaged
and solidified liquid radioactive
waste,
dated 9/27/79
79-026B
Radwaste
Shipping Cask,
dated
9/27/79
79-026C
79-035
1980
80-028
Radiation Protection
Procedures,
Section
V, Paragraph
2.0, Shipping
and Receiving of Radi'oactive Material, dated
9/27/79
Low Level Loading and Transportation of Radioactive klaste,
dated
12(21/79.
Radi'ation Protection
Procedures,
Section
V, Paragraph
2.0, Shipping
and Receiving of Radioactive Materi'al, dated
1/10/80
80-049
(Same
as 80-028}, dated ll/17/80
1981
81-039
Ouality Control - Operations,
by request of the Station Shift
Supervisor,
witnessed
the Dewatering of Spent
Resin
Cask,
dated
3/4/81
10 CFR 71, Appendix E, Criterion 18, Audits, states;
"A comprehensive
system of planned
and periodi'c audits shall
be carried out to verify
compliance with all aspects
of the quality assurance
program
and to
determine
the effectiveness
of the program.
The audits shall
be performed
in accordance
with the written procedures
or check lists
by appropriately
trained personnel
not having direct responsibilities
in the area
being
audited.
Audit results shall
be documented
and reviewed
by management
having responsibility in the area audited.
Followup action, including
re-audit. of deficient areas,
shall
be taken
where indicated. "
Audit 73-026A identified three
items for followup action:
(1} Station
Haste Handling Procedures
need completion
and final review; (2} Radiation
Protection
and Haste
shipment
documents-
need inclusion in the Document
Control System for compli;ance with ANSI 45.2.9;
(3} current vendor. survey
of Chem Nuclear Systems
Inc.
needs
to be complete.
The inspector
discussed
with a licensee
representative
what followup
action
had
been
taken to assure
that the three identified deficiencies
were corrected.
The licensee's
representative
indicated that once the
deficiency
had
been reported to management
by means of the audit report,
-subsequent
'audits
would not re-identify the
same deficiency if it still
existed.
The inspector determined
from a review that subsequent
audits
performed of the Radioactive
Haste
Hanagement
area
up to April 30,
1981
did not include
a re-audit of the deficient areas.
Additionally, it was
noted that audits
79-026A,
B, and
C were performed for compliance with
IE Bulletin 79-19, dated
August 10,,1979,
items
7 and 8.
stated
in part:
5.
Provide training and periodic retraining in the
DOT and
NRC
regulatory requirements,
the'aste
burial license requirements,
and in your instructions
and operating
- procedures
for all
personnel
involved in the transfer,
packaging
and transport of
radioactive material.
Haintain
a record of training dates,
attendees,
and subject materi'al for future inspections
by
NRC
personnel.
6.
Provide training and periodic retraining to=-those
employees
who
operate
the processes
which generate
waste to assure
that the
volume of low-level radioactive waste is minimized and that
such waste is processed
into acceptable
chemical
and physical
form for transfer
and shipment to
a low-level radioactive waste
burial facili.ty.
I
7.
Establish
and implement
a management-controlled
audit function
of all transfer,
packaging
and transport activities to provide
assurance
that personnel,
instructions
and procedures,
and
process
and transport
equipment are functioning to ensure
safety
and compli.ance with regulatory requirements.
8.
Perform, within 60 days of the date of this bulletin,
a management-
controlled audit of your activities'ssociated
with the transfer,
packaging
and transport of low-level radioactive waste.
Maintain
a record of all audits for future inspections
by
NRC or
inspectors.
(Note: If you have
an established
audi t function
and
have performed
such
an audit of all activities in Item 1-6
within the past six months, this audit requirement is satisfied.)
The above-menti'oned
audits
(Items
7 and 8) were incomplete in that no
audit was performed of the training requirements
specified in Items
5 and
6.
The inspector noted that the quality assurance
program is implemented
on
a modular basis with selected
portions completed during each audit.
Of
the sixty-five radioactive material
shipments
made in 1980, only two
audits were performed,
audits80-028
and 80-049,
both of which were
limited to the
same selected
portion of the overall program.
During the
period of January
through
May 1981,
twenty shipments of radioactive waste
were made,
one audit was conducted,
audit 81-039, at the request of the
Station Shift Supervisor.
There is no observable
pattern for repetitive
audits of each work operation for the entire radioactive waste
management
program.
The inspector
informed licensee
representatives
that failure to perform
a
complete audit of the radioactive
waste
management
program was noncompliance
with the requirements
of 10 CFR 71, Appendix
E (81-10-03}.
dd. ~Rdk
The inspector revi ewed the records of se1 ected radi oacti ve materi al
shipments
made
by the licensee
during the period January
1,
1979 through
December
31,
1979 and all shipments
made
from..January
1980 through April
1981, for compliance with the requirements
of 10 CFR 71.62.
The licensee
maintains
a record of all radioacti've material
shipments for a period in
excess of the two-year requirement.
The record is completed with all
shipping documentation,
including the receipt
and shipping 'radiation
sur vey data.
No items of noncompliance
were identified in this area.
11.
Exit Interview
The inspector
met with the licensee
representatives
(denoted in paragraph
1) at the conclusion of the inspection
on May 1,
1981.
The inspector
summarized
the scope of the inspection
and the findings.
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