ML18009A642
| ML18009A642 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/29/1990 |
| From: | Elliott M, Gloersen W, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18009A641 | List: |
| References | |
| 50-400-90-16, NUDOCS 9009130127 | |
| Download: ML18009A642 (22) | |
See also: IR 05000400/1990016
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
~E~O4 eo
Report Ho.:
50-400/90-16
Licensee:
Carolina
Power and Light Company
P. 0.
Box 1551
Raleigh,
HC
27602
Docket Ho.:
50-400
Facility Name:
Shearon Harris
License Ho.:
HPF-63
Inspection
Conducted:
August 6-10,
1990
Inspectors
.,G oerse
. El glott
Approved by:
J.
P. Potter, Chief
Facilities and Radiation Protection Section
Emergency
Preparedness
and Radiological
Protection
Branch
Division of Radiation Safety
and Safeguards
ate
gne
F
2f'te
gne
So
Date Signed
SUER Y
Scope:
This routine,
unannounced
inspection
was conducted
in the areas of occupational
radiation safety,
shipping of low-level radioactive
wastes
for disposal
and
transportation
of licensed
radioactive
materials,
Information Notices,
and
previously identified inspection
findings.
In addition,
the
inspectors
provided balanced,
minimum coverage for the resident
inspectors
during their
absence.
Results:
In the areas
inspected,
one apparent violation was identified for failure to
secure
licensed radioactive materials
stored in an unrestricted
area
(Warehouse
'No. 6) from unauthorized
removal
from the place of storage.
The licensee
made
several
purchases
of new equipment to erhance
the radiation protection
program
which included:
bag monitor, tool monitor, portable respiratory fit testing
facility, and
a "portable" dedicated
breathing air system.
REPORT
DETAILS
Person's
Contacted
Licensee
Employees
Vi. Boone, Radiological Control
(RC)
Foreman
W. Cerame,
Senior
RC Technician
- A. Cornett,
RC Foreman
J. Floyd,
RC Foreman
S. Frost,
RC Technician
"J.
Hammond,
Manager,
Gnsite Nuclear, Safety
"C. Hinnant, Plant Ceneral
Manager
- A. Howe, Senior Specialist,
Regulatory Compliance
- J. Kiser,
RC Supervisor
- C. YcKenzie, Manager,
gA Engineering
- G. Olive, Specialist Security
<<A. Poland, Project Specialist,
RC
F. Reck,
RC Foreman
J. Sipp, Manager,
Environmental
and Padiological
Control
(E&RC)
"D. Stih,
ALARA Technician
<<M. Wallace, Senior Specialist,
Regulatory Compliance
E. Wills, Technical
Support Specialist
Other
licensee
employees
contacted
during this
inspection
included
engineers,
operators,
technicians,
and administrative
personnel.
- Attended exit interview
Audits and Appraisals
(83750)
Technical Specification (TS) 6.5.4.1 requires audits of unit activities to
be
performed
by the Ouality Assurance
(gA) Services
Section
of the
Corporate
gA Department,
including:
(1) conformance of unit operation to
provisions contained within the
TSs ard applicable
license conditions, at
least
once
per
12 months;
(2) the performance
of activities required
by
the Operational
gA program to meet the criteria of Appendix B, 10 CFR 50,
at least
once
per
24 months;
and
(3) the
Process
Control
Program
and
implementing
procedures
for processing
and
packaging
of radioactive
wastes,
at least
once per 24 months.
The inspectors
discussed
the audit and surveillance
program with licensee
representatives
in the areas of radwaste
shipping, contamination, control,
radiation protection,
and
CLARA program
implementation.
The inspectors
reviewed the following guality Assurance
Audit (gAA) and Surveillances:
gAA/0022 - 89-03:
Audit of the Environmental
and Radiation Control
Program, July 10-21,
1989
I
Surveillance
89-056:
Independent
Radiation Survey, April 1989
Surveillance
89-058:
Radwaste
Shipping, April 1989
Surveillance
89-069:
Fuel
Cask Activities, May 1989
5:
Radwaste
Shi
in
Na
1989
Surveillance
89 07
pp
g
Surveillance
89-080:
ALARA Program Implementation,
June
1989
Surveillance
89-096:
Spent
Fuel Receipt,
August 1989
Surveillance
89-139:
Refueling Outage,
December
1989
Surveillance
90-016:
Contamination Control, February
1990
Surveillance
90-023:
Health Physics,
February
1990
Surveillance
90-046:
Fuel
Cask Activities, May 1990
The reports of audit findings to management
were also reviewed
and found
to contain
responsive
corn:itments
by
management
to effect corrective
actions for the deficiencies
noted.
The
inspectors
also
reviewed
the
licensee's
program
for
self-identification of weaknesses
related
to the radiation protection
program
and
the appropriateness
of the corrective actions
taken.
This
area
had
been previously reviewed
and identified as
an Inspector
Followup
Item (IFI) (50-400/89-23-01).
In that report, it was
noted that the
licensee
was documenting
events
arid corrective actions taken in letters to
plant files.
The use of the letters to plant files did not implemert the
aspects
of the Radiation
Safety Violation
(RSY) Reporting
System that
would
assure
effective
root
cause
corrective
action.
Since
that
inispection,
the licensee
had revised
procedure
ERC-20l.,
"EImRC Feedback
Report," January
12,
1990, Revision 1, to include criteria for initiating
investigations of radiological incidents.
The Feedback
Report System
was
designed
to provide tracking for the initiation, conduct
and results of
these
investigations.
Durino this inspection,
the inspectors
reviewed
RSVs for 1990 and noted that only five RSVs
had been documented.
Feedback
Reports
were not reviewed during this inspection.
Due to the relatively
few
RSVs available for review, it was difficult to determine
whether
licensee
identified deficicrcies
were properly addressed.
The licensee
was
irformed that
the
previously
identified IFI (50-400/89-23-01),
including the
new
Feedback
Report
System,
would
be reviewed during
a
subsequent
inspection
wheni more data are available.
Ko violations or deviations were identified.
3
Changes
{83750)
The inspectors
reviewed
any major changes
since
the last inspection
in
organization,
facilities,
equipment,
and
programs
that
may affect
occupational
radiation
protection.-
The
Environmental
and
Radiation
Control
(BRC) organization
had
been
reorganized
which mainly involved
program area
reassignments
to the various
RC foremen.
The reorganization
did not result
in
any significant reduction
in force.
The
organization
consisted
of
a
Ranager,
RC
Supervisor,
ALARA Senior
Specialist,
and four
RC
Foremen..
The licensee's
RC technician staff
levels were comparable
to other facilities of the
same size
and design
and
were considered
adequate
to acccmplish
the radiation protection
program
objectives.
In addition,
the
ESRC organization
had
a technical
support
group
consisting
of
a
project specialist
and
ten technical
support
specialists.
The
inspectors
also
noted that the licensee's
Corporate
Health Physics
(HP) group
had undergone
an organizational
analysis within
the last year which resulted
in
a loss of some
key technical
support
personnel,
including a radwaste
technical
support specialist,
and
a minor
reduction in force.
It was noted that
a corporate
dose reduction steering
committee
was established
in April 1990 to identify and
implement
dose
reduction
actions
and
programs.
The
adequacy
of Corporate
HP staff
involvement in, and support of plant radiation protection program
and dose
reduction
program should
be evaluated
durin'g subsequent
inspections after
the corporate
programs
have
been fully implemented.
The inspectors
also
observed
that the licensee
had
made major equipment
purchases
to
enhance
the radiation protection
and radioactive material
control
programs.
The
new equipment
purchases
included:
bag monitor,
tool monitor, portable respiratory fit testing facility, and
a dedicated
compressor
arid breathing air system.
No violations or deviations
were identified.
External
Exposure Control
(83750)
10 CFR 20.202{a)
requires
a
licenisee
to supply appropriate
personinel
monitoring equipment to,
and require
the
use of such
equipment
by each
individual
who enters
a restricted
area
under such circumstances
that
he
receives,
or is likely to receive,
a
dose in any calendar
quarter in
excess of 25 percent of the limits in 20.101.
10 CFR 20.202(c) requires all personnel
dosimeters
(except for direct and
indirect reading pocket ionization chambers
and those
Cosimeters
used to
measure
the dose to the hands
and forearms, feet,
and ankles) that require
processing
to determine
the radiation
dose
and that are utilized by
licensees
to
comply with paragraph
(a) of this section,
with other
,applicable provisions of 10
CFR Chapter I, or with conditions specified in
a
licenisee's
license
to
be
processed
and
evaluated
by
a
dosimetry
processor
holding current
personnel
dosimetry accreditation
for the
appropriate
type of radiation
or radiations
being monitored
from the
National
Voluntary
Laboratory
Accreditation
Program
(NYLAP) of the
National Institute of Standards
and Technology.
10 CFR 20.408{b) and 20.409(a)
requires
a licensee
to notify and report to
the
Ccmrission
and
the
individual,
the radiation
exposure
of the
individual involved upon termination of employment.
The inspectors
determined
by direct observation,
aiscussion,
and
a review
of procedures
that the licensee's
dosimetry program
was being conducted
in
accordance
with established
procedures
and
10 CFR 20 requirements.
The
inspectors
also verified through
discussions
with cognizant
licensee
personnel
that
the dosimetry
program
was accredited
by
NVLAP for the
radiations
being monitored.
The
inspectors
reviewed
employee
termination
Cata
from January
1990 to
August
1990.
The inspectcrs
compared
employee
termination
data with
actual letters that
had
been
sent to individuals after termination
and
verified that the licensee
was in compliance with 10 CFR 20.408
and 20.409
requirements.
During tours of the Radiologically Controlled Area
{RCA) on August 7-9,
1990,
the inspectors
observed
worker practices with regard to wearing and
placement of personnel
dosimetry.
The inspectors
did not identify any
problems with workers'osimetry practices.
No violations or deviations
were identified.
Internal
Exposure Control (83750)
10 CFR 20.103{a) requires
the licensee
to perform appropriate
bioassays
and
assess
intakes of radioactivity.
The inspectors
reviewed the whole
body counting
(WBC)
equipment
operation
and
discussed
counting
and
calibration
methods
with equipment
operators.
The licensee's
equipment consisted of two Nuclear Data, Inc. chair units.
The inspectors
reviewed
the
annual
calibration
records,
efficiency
curves,
and
procedures.
The calibrations
of the
two chairs
were
performed
on
January
18 and 22,
1990.
Additionally, the inspectors
reviewed the daily
quality control
(gC) checks
from January
1990 to July 1990,
and noted that
check
source activities
(Cs-137/Co-60)
and background counts were plotted
and tracked daily.
The licensee
also
uses
an Eu-152 source to perform
daily
energy
calibration
checks.
There
were
no
obvious
problems
associated
with these
data.
In general,
the
CC and calibration records
were well organized
and maintained.
The inspectors
also reviewed the licensee's
in-vitro bioassay
program.
The
licensee's
procedure
required
an individual to provide
a urine and/or fecal
sample if a confirmed whole body count measurement
was greater
than or
equal
to ten percent of the maximum permissible
organ burden
(l,POB).
The
licensee
uses
an offsite vendor to perform the analysis.
The inspectors
verified that during the last
12 months,
no individual had
a whole body
0
count
measurement
which
exceeded
the
licensee's
action
level of two
percent
MPGB.
No violations or deviations
were identified.
6,
Control
of Radioactive
Materials
and
Contamination,
Surveys,
and
Monitoring {B3750)
Radioactive Material Control
10 CFR 20.207{a)
requires
a
licensee
to
ensure
that
licensed
materials
stored
in
an
unrestricted
area
are
secured
from
unauthorized
removal
from the place of storage.
During routine tours of the facility, radioactive material
storage
areas
were
observed
inside
the restrictive
RCA and were marked
and
labeled
in accordance
with procedures.
Storage
areas
inside
the
protected
area
but outside,
the
RCA were
posted
and
locked secure.
The licensee's
RC personnel
informed the inspectors
of radioactive
material
storage
locations
outside
the protected
area in Warehouses
No.
5 and
No. 6.
The licensee
informed the inspectors that in order
to tour the
warehouses,
a
key would
have
to
be
obtained
from
security.
At approximately
1830
hours
on. Thursday,
August 9, the inspectors
coordinated with security to meet at Warehouse
No. 5,
The inspectors
were unable to locate
Warehouse
No. 5.
Licensee
personnel
working in
the
area
indicated that
Warehouse
No.
5 had
been
Corn
down after
plant construction.
The inspectors
discussed
with RC personnel
what
materials
were
supposed
to be in Warehouse
No.
5 and
had they been
accounted for when the building was tom down.
The licensee
had
no
inventory of what was .supposed
to be in either warehouse,
but assured
the inspectors that radioactive material
was only stored in Warehouse
No.
6 at this time.
The licensee
RC personnel
stated. they had vague
knowledge of the
warehouse
numbering
system
and at
one time
some
radioactive
material
had
been
stored
in
a
warehouse
complex
consisting of three buildings across
from Warehouse
No.
6 which they
had referred
to
as
Warehouse
No. 5.
This
complex
was correctly
identified as
Warehouses
No. 1, No. 2, and No. 3.
Upon arrival at Warehouse
No. 6, the inspectors
noted that security
,
personnel
were
not
needed
because
Warehouse
No.
6 was
open.
The
inspectors
toured the warehouse
and observed
three large
open doors
and miscellaneous
equipment
stored in the
open unrestricteo
part of
the warehouse.
On one erd of the warehouse,
the inspectors
observed
a
locked restrictea
storage
area.
The inspectors
noted that the
radioactive material
was stored in the
open
unsecured
pat t of the
warehouse.
The storage
area
was roped off and posted
"Raaioactive
Materials
Storage
Area,
Caution
Radioactive
Materials, Notify HP
Prior to Entry."
The inspectors
also observed that Warehouse
No.
6
was being used
as
a social picnic facility for contractor
personnel
ard that there
were
no apparent active personnel
access
restrictions
in place.
The next day, the inspectors
discussed
the. Varehouse
Ho.
6 situation
with cognizant licensee
personnel..
The licensee
had neither recent
surveys of the radioactive materials
storage
area
nor an inventory of
the material
in storage.
The inspectors
discussed
with the licensee
concerns
about the security of the radioactive material
and whether
the licensee
had active controls
over the area
by which to prevent
unauthorized
removal of the radioactive material
from the authorized
storage
location.
The licensee
ensured
the inspectors
that the
warehouse
personnel
maintained strict control over all items entering
and exiting Marehouse
No. 6.
On Friday,
August 10, at
1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />,'he
inspectors
entered,and
toured all accessible
areas
to Marehouse
No.
6 which included the
radioactive
materials
storage
area,
and neither
observed
nor
was
confronted
by aryone.
The inspectors
also
noted that
one item,
a
55 gallon
drum containing
cortaminated
equipment,
contained
a label
indicating radiation levels of 60 milliroentgens per hour (mR/hr) and
.was properly posted
as
a radiation area.
The inspectors
determined
that Varehouse
Ho.
6 was
an unrestricted
area
and that the licensee
did
not
have
active
controls ir place
to
secure
the
stored
radioactive material against
unauthorized
reaoval
from the designated
storage location.
The licensee
was informed that the question
on the proper security of
licensed material
stored in an unrestricted
area would be considered
an
unresolved
item" until
RII
management
had
reviewed
the
circumstances.
On
August 14,
1990,
the
inspectors
contacted
the
licensee
by
telephone
to discuss
the situation.
The
licensee
informed the
inspectors
that
surveys
performed
on the
55 gallon
drum indicated
radiation levels of 60-80 mR/hr and that the fuel racks stored in
warehouse
No.
6
had
been
moved inside
the protected
area
and the
decortamination
equipment
had
been
shipped offsite.
The inspectors
informed the licensee that the failure to properly secure radioactive
materials stored in an unrestricted
area
was
an apparert violation of
requirements
(50-400/90-16-01).
Cne violation for failure to properly secure
licensed material stored
in an unrestricted
area
was identified.
A
l >> .~lh>> lf .ti
I
ql
4
ascertain
whether it is an'cceptable
item,
a deviation, or violation.
b.
Personnel
Contamination
Events
and Surveys
and
20.401 require the licensee
to perform surveys
and to maintain
records of such
surveys
to det onstrate
compliance
with regulatory limits, respectively.
The inspector
reviewed
records
of personnel
contamination
events
(PCEs) for the
1989 refueling outage
and through June
1990.
During
the
1989 refueling outage,
the licensee
experienced
93
(21 skin
and
72 clothing).
The plant
goal for the
outage
was
25 skin
ccntaminations
and
75 clothing cortaminations.
The
number of PCEs
had significantly decreased
from the first refueling outage
(191
PCEs:
86 skin and
105 clothing).
During the
1989 outage,
45
involved contamination
levels
less
than or=equal
to 500 net counts
per
minute
(ncpm),
which
indicates
generally
low levels
of
contamination
in the work areas.
Nine
PCEs involved contamination
levels greater
than
5,000
ncpm.
The licensee
identified
18
occurring in areas
designated
as clean.
The licensee
made similar
observations
during the first refueling outage
and noted that there
appears
to
be
some
continued
spread
of low level
contamination
outside
posted
area's.
The
number of PCEs through June
1990 was 32.
The
licensee
had established
a
goal of 52
PCEs.
Nineteen
occurred in'he
Fuel
Handling Building (FHB)
due to the
increased
activities associated
with spent
fuel received
from the Brunswick
project.
No violations or deviations
were identified.
7.
Naintaining Occupational
Exposures
ALARA (83750)
10 CFR 20.1(c') states
that licensees
should
make every reasonable
effort
to maintain radiation
exposures
as far below the limits specified in
Part 20
as
is reasonably
achievable.
Regulatory
Guides
8.8
and 8.10
provide
information relevant
to attaining
goals
and
objectives
for
planning
and
operating
light-water
reactors
and
provide
a
ceneral
operating
philosophy
acceptable
to the
hRC
as
a necessary
basis for a
program of maintaining
occupational
exposures
as
low
as
reasonably
achievable
(ALARA).
a ~
Radiation Source
and Field Control
The
inspectors
reviewed
the licensee's
plans
to utilize proven
industry-developed
methods
of controlling out-of-core
radiation
sources
and fields.
Since the licensee's facility was relatively new
and there
has
been
no significant fuel integrity problems,
unusual
efforts
to
reduce
source
tera.
have
not
been
necessary.
The
licer,see's
corporate office had recently established
a dose reduction
committee
which
was
tasked with identifying and
implementing
dose
reduction
actions
and
programs
for the
three
nuclear
projects:
Brunswick, Harris,
and
Robinson.
For the Harris Project,
the
committee
made the following recommendations:
Resistance
thermocouple
detector
'alve maintenance
pro gram
Cobalt reduction
program
Improved outage
planning
Contract incentives
During the
second
refueling outage,
at shutdown,
the licensee
added
peroxide
to the primary system to induce
crud bursts for
subsequent
removal
of radioactive
(mainly Co-58)
which had
become
soluble
during
the
peroxide
addition.
The
solubilized "crud" was
then
removed
by the purification system ion
exchargers.
The chemical
volume control system
(CVCS) letdown flow
was maintained at
120
gpm through one mixed bed demineralizer
and the
cation deoireralizer for crud removal.
During the
85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> after the
initial
peroxide
aCCition
and
until
flow was
terminated,
approximately
1,370 curies
of Co-58 (calcul'ated)
was
removed from the reactor coolant system
(RCS).
Licensee
Awareness
and Involvement
The
inspectors
discus'sed
with licensee
representatives,
workers'wareness
and
involvement
in the
ALARA proaram.
The inspectors
observed
that
tt e
licensee
had
an
ALARA suggestion
program
established;
however, participation in the program has
been limited.
Since
1985,
44 suggestions
have
been
submitteo.
As of August 9,
1990, only two ALARA sugaestions
have
been submitted.
At the time of
this inspection,
the licensee still had
19
ALARA action
items open.
The licensee
had identified this
ALARA program
weakness
and
had
initiated a plan to develop
an
CLARA suggestion
incentive program and
a tracking .program to resolve
previously identified
ALARA .action
items.
In addition,
the
inspectors
and
licensee
representatives
discussed
the
need
to
improve the
system for providing
prompt
feedback to ALARA suggestion
participants.
The
inspectors
also
reviewed
the
licensee's
ALARA coomittee
organization
and neeting
rr'inutes for 1990.
The ALARA subcomrittee
chairman
was
the
ALARA specialist.
The
committee
consisted
of a
Cesianated
or alternate
representative
from the following groups:
Administratior:,
Yiaintenance,
Cperations,
Vodifications,
gA/gC,
Training,
Environmental
and
Ctemistry,
Technical
Support,
HP,
Planning
and Scheduling,
and Plant Nuclear Safety
Comnittee.
The
comnittee
met at least
once
per month or as- needed
to discuss
suggestions,
collective
dose
goals,
objectives,
high-dose
(greater
than
25 man-rem) job reviews,
and other
ALARA concerns.
During 1990,
committee
meeting
attendance
was generally
good except
during Dune
1990
when only 50 percent of the departmental
representatives
were
present.
During the second refueling outage,
the
ALARA Subcoamittee
reviewed only two high dose jobs which were greater
than or equal to
25 man-rem
as
required
by AP-502,
ALARA SubcottIIittee,
Revision 2,
April 22,
1988.
The inspectors
discussed
with the licensee
the need
to consider
lowering the threshold for ALARA Subcommittee
pre-job
c
~
reviews to ensure that
some of the lower dose higher volume jnts vere
receivin'9 proper management
review.
ALARA Goals
and Objectives
The
inspectors
discussed
with licensee
representatives
the
1990
station collective
dose
goal
and
the
second
refueling outage
dose
goal,
and
how the licensee
was tracking
and oeeting those goals.
In
addition, the inspectors
reviewed the licensee's
ALARA report for the
second
refueling outage
October
10 through
december
22,
1989.
The
procedure
was generally well written and organized
and included the
following items:
( 1)
corrective
action
recommendations
for
procedural, material, design,
organizational,
and good practices;
{2)
ALARA cl.tage
dose goals,
corItamination goals,
and radioactive
waste
goals;
(3) refueling
outage
performance
su@varies,
including
hydrogen peroxide treatment,
accumulator venting
an'd effluert release
assessment
during 'the integrated
leak rate test;
and (4) ALARA job
evaluation suwraries.
The collective dose
goal for the
second refueling outage
(1989)
was
120 man-rem,
including 20 man-rem for what the licensee
described
as
"emergent"
dose.
Emergent
dose
was defined
as
dose
which becalm
necessary
after the outage
had
begun
{unplanned work); for example,
additional
testing
and
plugging of steam
generator
tubes.
The actual
collective
dose for the
1989
outage
was
137
own-rem;
including
11 man-rem for emergent
work.
The amount of collective
Ccse
due to rework was approximately
two man-rem.
awhile the goal for
planned
work was
exceeded,
the total collective dose
was still
a
significant decrease
from the
154 man-rem
expended
during the first
refueling outage.
The total station collective
dose in 1989
was'55
person-rem
which
was significantly below the
1989
national
average of 292 person-rem for PkRs.
The inspectors
also reviewed the
licensee's
1990 collective dose
goal
and performance.
The licensee's
1990 collective dose
goal
was set at 72 person-rem
since there
was
no
refuelirg outage, scheduled
for 1990.
As of August 8,
1990,
the
station's
actual collective dose
was
43 person-rem.
The collective
dose
due tc movement
and storage of spent fuel from the 8runswick and
Robinson
projects
was approximately
10 man-rem.
The licensee
had
established
a goal of 12 man-rem for the spent fuel activities.
Ho. violations or deviations
were identified.
B.
Radwaste
and Transportation
(83750)
10 .CFR 20.311(d)(1)
requires
any
generating
licensee
who
transfers
radioactive
vraste
to
a
land
disposal
facility or
a licensed
waste
collector to prepare all wastes
so that the waste is classified according
to
requiret ents
ard
meets
the
waste
characteristic
requirements
10
requires
each
licensee
who transpcrts
licensed
material
outside
the confines of its plant or other place of use,
to comply with
the applicable
requireaants
of the regulations
appropriate
to the mode of
transport
of the
Department
cf Transportation .(GGT) in
45
CFR parts
170-1G9.
49
CFR 172.200 requires
each
person
who offers
a hazardous
material for
transportation
to describe
the hazardous
material
on the shipping'aper
in
the manner described
by this subpar t.
10 CFR 71.137 requires
a licensee
to carry out a comprehensive
system of
planned
periodic audits
to verify compliance with all aspects
of the
quality assurance
program
and
to
. determine
the effectiveness
of the
program.
The inspectors
reviewed shipping
papers
fr'om December
1989 to August 1990
ard verified they contaired
the information required
by 49
CFR 172.200.
The inspector
noted that shipping
papers for shipment
No. 0790-072
on or
about*duly 5,
1990 designated
the shipping
package
to be
a
USDOT 7A Type A
(7A) container with a
NPC Certificate of Compliance
(COC) No. USA/9073/A.
The
inspector
asked
the
licensee
for documentation
demonstrating
the
package
used
met
7A specifications
as required
by 49
CFR 173.415(a).
The
licensee
did not have
the required
documentation;
however,
the licensee
, claimed, to
be
exempt
from the
49
CFR 173.415(a)
requirement
because
the
shipment contained greater
than Type
A quantities of Low Specific Activity
(LSA) waste.
The licensee
stated that greater
than Type
A quantities
are
tc be shipped in Type
B packages;
however,
10 CFR 71.52 exempts
the Type
B
package
requirement for LSA shipmerts,
10 CFR 71.52 also states
package
safety
performance criteria that must
be met by packages
used
under this
exemption.
The container
used,
a Radlock
500 High Integrity Container
(HIC), did meet the
1G
CFR 71.52 requirements
as evidenced
by the
COC.
The
inspectors
advised
the licensee;
after consultation
with the
NRC
Transportation
Branch Chief, Division of Safeguards
and Transportation,
Office of Nuclear Yiaterials Safety
and Safeguar ds; that
when the Radlock
5GO
HIC was
used to ship anything other than. Type A quantities,
the
number
(USA/9073/A)
serves
as
the
proper
package
designation
on the
shipping
paper.
Mhen the
Radlock
500
HIC is
used
to ship
Type A
quantities it should
be designated
as
a
7A package
on the shipping paper.
The
inspector
discussed
with
the
licensee
potential
confusing
circumstances
concerning
the quantities
inside the package, that may arise
durirg an accident situation
because
the
package
had
been
designated
as
both
a
7A and
a
COC specification
package.
The licensee
stated
that the staff had
been
advised of this matter
and
will properly designate
the container
when
used
in the future.
Also,
since
the licensee
may be shipping
Type
A quantities in the future using
the
Rad Lock 500 HIC, the licensee
requested
copies of the
7A performance
test records
from the manufacturer.
These
records
are required to be on
file for at least
one year after each shipment using
a
7A package.
11
The inspectors
reviewed
gA reports for transportatior
audits
conducted
frcm Yarch 1989 to July 1990.
The inspector verified that the audits
were
in accordance
with the licersees
established
gA procedures.
The audit
reports
reviewed indicated
nc discrepancies
with site
and
DOT shipping
requirements.
The inspectors
discussed
the waste classfffcaf,icn process
and procedures
with cognizant
licensee
personnel
respcnsible
for the task.
The licensee
uses
vendor
services
for analysis of the waste.
The inspector verified
that waste classifications
complied with 10 CFR 61 requirements.
No violations or deviations
were identified.
9.
Previously'dentified
Inspection
Findings
(92701,
92702)
a.
(Closed) Violation 50-400/88-28-01:
Failure to provide
a radiation
monitoring device to
an individual entering
Inspection
Peport
ho. 50-400/89-29
documented
a review of the
above
violaticn and it was determined
that the corrective actions
had not
been
documented
in
a procedure.
The inspectors
revfewed procedure
revisions
to AP-.504, "Administrative Controls for Locked/Restricted
High Radiation Areas," Revision 2,
December
1, 1989,
and noted that
the corrective actions
had
been adequately
addressed
by AP-504.
This
item is considered
closed.
b.
(Closed)
IFI 50-400/88-28-03:
Proper
use of protective clothing (PC)
by plant personnel.
During routine tours of the plant, including the
Auxiliary Huflding, the
inspectors
observed
a team of individuals
properly wearing their protective clothing
and respirators
while
repairing a'alve.
The inspectors
also reviewed several
PCE reports
and noted that most of the
PCEs involved foot and leg contaa~inatfon
on the clothing.
No chest or abdomen contamfnations of the skin were
noted
indicating
that
the
individuals
were at least
properly
fastening their
PCs.
There
were
nc
RSVs for improper
PC dressing
identified in 1990.
This item fs considered
closed.
10.
Exit Interview
The inspectors
met with licensee
representatives
(denoted fn Paragraph
1)
at the conclusion of the inspection
on August 10,
1990.
The inspectors
summarized
the
scope
and
findings of the inspection,
including the
unresolved
item.
The inspectors
also discussed
the likely informational
content of the inspection report with regard
to dccuments
or processes
reviewed
by the inspectors
during the inspection.
The licensee
did not
identify any
such
documents
or processes
as
proprietary.
During
a
telephone
conversation
on
August 14,
1990,
the
inspectors
informed
licensee
representatives
that
the
unresolved
item pertaining
to the
apparent failure to secure
licensed
radioactive materials
stored
fn an
unrestricted
area
(Varehouse
No. 6) from unauthorized
removal
from the
place of storage
was reviewed
by regional
management
and was considered
as
12
a violation of 10 CFR 20.207.
Dissenting contents
here riot received
from
the licenisee.
Item Number
50-400/90-16-01
Descri tion and Reference
VIO -
Failure
to
.secure
licensed
radioactive
materials
stoied
in
an
unrestricted
area
(Warehouse
No. 6)
from unauthorized
removal
from
the
place of storage
(Paragraph
6).