ML17251A795
| ML17251A795 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/08/1986 |
| From: | Clemons P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17251A793 | List: |
| References | |
| 50-244-86-15, NUDOCS 8609230248 | |
| Download: ML17251A795 (12) | |
See also: IR 05000244/1986015
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No.
50-244/86-15
Docket No.
50-244
License
No.
Pri ority
Category
C
Licensee:
Rochester
Gas
and Electric Cor oration
49 East Avenue
Rochester
14649
Facility Name:
AR.
E. Ginna Nuclear
Power Plant
Inspection At:
Ontario
Inspection
Conducted:
Au ust 11-15
1986
Inspector:
P.
Clemons
Radiation Specialist
ate
Approved by:
W.
Pas
, Chief, Effluents Radiation
Protection
Section
d
e
Ins ection Summar:
Ins ection
on Au ust 11-15
1986
Re ort No. 50-244/86-15
A~d:
f,
f
activities including:
purpose,
management
controls, training, procedures,
shipments of radioactive material, quality control, Part 61,
and package
selection.
Results:
Two violations were identified (fai lure to identify Iron-55, its
activity, and the correct total activity on shipping manifests,
paragraph
4;
and the fai lure to develop
and implement
a guality Control Inspection
procedure
for the dewatering
process,
paragraph
5).
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DETAILS
1.0
Persons
Contacted
1.1
Licensee
Personnel
R. Kober, Vice President,
Electric Production
B. Snow, Superintendent,
Nuclear Production
S. Spector,
Superintendent,
Ginna Production
C. Anderson,
Manager,
Quality Assurance
D. Fi lkins, Manager,
Health Physics
and Chemistry
D. Fi lion, Radiochemist
W. Stiewe, Quality Control Engineer
S. Warren,
Health Physicist
P.
Spacher,
Health Physicist
W. Goodman,
Health Physics
Foreman
C. Kimball, Senior Quality Assurance
Specialist (Contractor)
1.2
NRC Personnel
J.
Kim, Reactor
Engineer
Other licensee
personnel
were contacted
and interviewed during this
inspection.
2.0
~Pur ose
The purpose of this routine inspection
was to review the licensee's
program with respect to the following areas:
Review of management
controls;
Review of training;
Review of procedures;
Review of shipments of radioactive material;
Review of quality control;
Review of Part 61;
and
Review of package
selection.
3.0
Mana ement Control
The licensee
has
documented
the management
control for radioactive
waste
management
in an administrative
procedure for the Health Physicist/
Radioactive
Waste Coordinator.
Procedure
No. A-201, "Ginna Station Admin-
istrativee
and Engineering Staff Responsibilities,"
contains
the general
job description,
and responsibilities for transportation activities
involving radioactive waste.
All of the activities are
governed
by procedures
which specify methods for
handling,
processing,
sampling,
and analyses
of liquid radioactive waste;
directions for operating plant systems
to control
and process
radioactive
waste;
and methods for control
and processing
of solid radioactive waste.
Within the
scope of this review,
no violations were identified.
4.0
Shi ments of Radioactive Material
The transportation
of licensed material
was reviewed against
the criteria
contained
in 10
CFR 71, "Packaging
and Transportation of Radioactive
Material,"
10
CFR 20.311,
"Transfer for Disposal
and Manifests,"
and
49
CFR 172.203,
"Additional Description Requirements."
The licensee's
performance relative to these criteria was determined
from
discussions
with the Health Physicist/Radioactive
Waste Coordinator,
the
Manager of Health Physics
and Chemistry,
and by reviewing appropriate
documents.
Within the
scope of this review, the following violation was identified.
10
CFR 20.311(b),
"Transfer for Disposal
and Manifests," requires,
in
part, that the manifest
accompanying
radioactive
waste
shipments
indicate
as completely
as practicable
the radionuclide identity and quantity,
and
the total radioactivity of the shipment.
49
CFR 172.203(d),
"Additional Description Requirements,"
also requires
that the
name of each radionuclide in the radioactive material
must be
included
on the shipping papers.
The inspector determined that the licensee failed to identify the radio-
nuclide Iron-55,
and its activity, on any shipping manifests during the
period of January
1983
June
1985.
The licensee
made
several
shipments
of radioactive
waste material during this period.
The inspector determined that the licensee
issued
a purchase
order to
a
vendor dated October 26,
1982, requiring the vendor to provide analysis
on Ginna's waste
stream for radionuclides identified in Tables
1 and
2 of
10
CFR 61.55,
"Waste Classification."
Iron-55,
and other radionuclides,
are not identified in these tables.
The licensee
did not require this
vendor to perform
a complete radionuclide analysis,
therefore,
the
licensee did not identify the presence
of Iron-55 in the various waste
streams.
The inspector
reviewed copies of two purchase
requisitions that
are in the process
of being issued
as
a purchase
order,
but again the
licensee is not requesting
a complete radionuclide analysis.
According
to the documents
reviewed
by the inspector,
Iron-55 was first identified
in a shipment of dewatered filters that occurred
around
November
17,
1985.
This was the only shipment during the two year period in which Iron-55
was identified on the shipping manifest
as required.
Effective January
1984,
the licensee's
Effluent Technical Specifications
required the licensee
to sample
and analyze for Iron-55 in the gaseous
and
liquid discharges
to the environs.
This was done,
and Iron-55 was iden-
tified in these discharges.
Since Iron-55 was not identified,
and its activity determined for each
shipment,
the manifests
accompanying
each
shipment contained incorrect
total activities for those
shipments.
5.0
Failure to identify Iron-55, determine its activity in each
shipment,
and
include the radionuclide in the total radioactivity of the shipment con-
stitutes
a violation of 10
CFR 20.311(b)
(244/86-15-01).
Procedures
The adequacy
and effectiveness
of the licensee's
procedures
were reviewed
against
the criteria contained
in Technical Specification 6.8,
"Procedures."
The licensee's
performance relative to these criteria was determined
by
discussion with the Health Physicist/Radioactive
Waste Coordinator
and
Quality Assurance/Quality
Control personnel,
and by reviewing certain
procedures.
Within the
scope of this review, the following violation was identified.
On August 13,
1986, Quality Assurance/Quality
Control
(QA/QC) personnel
were questioned
as to their inspection activities associated
with the
shipment of radioactive waste material.
The inspector
was told that the
QA/QC personnel
performed their inspection activities in accord with
procedures,
and the inspector
was given
a copy of Procedure
No. QCIP-21.2,
"Shipping Package
HN-100 Series
2,
2A,
3 and
3A Inspection for Shipment."
The inspector
noted that the procedure did not address
the dewatering
process.
Package
No.
HN-100 Series
3 was used in the shipment of
dewatered
resins
on Nay 21,
1985.
The inspector
asked
licensee
repre-
sentatives
how Procedure
No. QCIP-21.2 could be used if it did not address
the dewatering
process.
The response
was "that was the procedure
used."
Technical Specification 6.8, "Procedures,"
requires that procedures
be
established,
implemented,
and maintained.
Procedure
No. A-1001, "Inspec-
tion and Surveillance Activities," developed
pursuant
to the above,
requires,
in part, that quality requirements
obtained
from regulatory
requirements
shall
be included in Quality Control Inspection
procedures.
10
CFR 20.311(d)(3),
"Transfer for Disposal
and Nanifests," requires
the
licensee
to conduct
a quality control program to assure
compliance with
10
CFR 61.56,
"Waste Characteristics."
4
~
10
CFR 61.56 is
a regulatory requirement that has quality requirements,
and the licensee
has not developed
a guality Control Inspection
procedure
. to capture
the quality requirements
associated
with the dewatering
process.
6.0
The failure to develop
and implement procedures
as required represents
a
violation of Technical Specification 6.8, "Procedures,"
(244/86-15-02).
~Trainin
Personnel
training in transportation activities was reviewed against
the
criteria contained
in 10
CFR 71. 105, "guality Assurance
Program,"
and IE
Bulletin No. 79-19,
"Packaging of Low-Level Radioactive
Waste for Trans-
port and Burial."
The licensee's
performance relative to these criteria was determined
by
discussion with training personnel,
Central
Records,
and by reviewing
appropriate
documents.
Within the
scope of this review,
no violations were identified.
7 '
Selection of Packa in
The licensee's
program for the selection of packages
was reviewed against
the requirements
of 10
CFR 71. 12, "General
License:
NRC Approved Package,"
and the Department of Transportation
(DOT) requirements
of 49
CFR 173,
"Shippers
General
Requirements
for Shipments
and Packaging."
The licensee's
performance relative to the criteria was determined
by
interviews of the Health Physicist/Radioactive
Waste Coordinator,
exam-
inations of documents,
procedures,
shipping records,
and observations
during plant tours.
Within the
scope of this review,
no violations were identified.
8.0
Part
61
The adequacy
and effectiveness
of the licensee's
program was reviewed
against
the criteria contained
in 10
CFR 61.55,
"Waste Classification,"
and
10
CFR 61.56,
"Waste Characteristics."
The licensee's
performance relative to these criteria was determined
by
discussion with the Health Physicist/Radioactive
Waste Coordinator,
and
by reviewing appropriate
documents.
Findings related to this area
are
discussed
in Section 4.0 of this report.
I
1
9.0
Exit Interview
The inspector
met with the licensee
representatives
(denoted
in Para-
graph
1) at the conclusion of the inspection
on August 15,
1986.
The
inspector
summarized
the
scope of the inspection
and findings as
described
in this report.
At no time during this inspection
was written material
provided to the
licensee
by the inspector.
a
'S