ML19343A678
| ML19343A678 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/07/1980 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19343A674 | List: |
| References | |
| 50-029-79-15, 50-29-79-15, IEB-79-19, NUDOCS 8011190632 | |
| Download: ML19343A678 (9) | |
See also: IR 05000029/1979015
Text
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O
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-29/79-15
Docket No.
50-29
License No.
OPR-3
Priority
Category
C
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Licensee:
Yankee Atomic Electric Company
20 Turnpike Road
Westborough, Massachusetts
Facility Name:
Yankee Nuclear Power Station (Yankee-Rowe)
Inspection At:
Rowe, Massachusetts
Inspection Conducted:
December 13-14, 1979
Irispector
h.
'J - 6 - 8 0
arl E. Plumlee, Radiation Specialist
date
date
date
3 ' 7' I 8
Approved by:
e
--
,
Feter J. Knapp, Chief, Radiation Support Section
date
Fuel Facilities and Materials Safety Branch
Inspection Summary:
Insoection on December 13 and 14, 1979 (Report No. 50-29/79-15)
Special unannounced inspection by a NRC regional based inspector of licensee's
response to IE Bulletin 79-19 including a review of copies of 00T and NRC regu-
lations maintained on site, procedures, training of personnel, records, audits,
,
and Quality Assurance relating to the transfer, packaging and shipping of low
level radioactive waste material.
The inspection involved 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on site by
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one NRC regional based inspector.
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Results:
No items of noncompliance were identified.
Region I Form 167
(August 1979)
80131.sola32
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OETAILS
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1.
Persons Contacted
- H. Autio, Plant Superintendent
- G. Babineau, Technical Assistant, Health Physics
- W. Billings, Chemistry and Health Physics Supervisor
- L. Bingham, Plant Operations Quality Assurance Coordinator (0QAC)
"L. Boutwell, Assistant to the Plant Superintendent
T. Danek, Operations Supervisor
- L. French, Engineering Assistant
"L.
Reed, OQAC
- N. St. Laurent, Assistant Plant Superintendent
- J. Staub, Technical Assistant to the Plant Superintendent
- Denotes those present at the exit interview, December 14, 1979, 4 p.m.
2.
Review of Licensee's Response to IE Bulletin 79-19
The inspector reviewed licensee's response to IE Bulletin 79-19 inoffice
to assure that all information required by the bulletin was included, and
to ascertain that corrective action commitments were also included.
Fur-
ther information concerning the response is given in Paragraph 10 requiring
additional information from the licensee.
3.
Organization
The Plant Health Physicist and the Technical Assistant-Health Physics,
acting for him, are the individuals responsible for the safe transfer,
packaging and transport of low level radioactive waste material.
Procedure
No. OP 8301, " Radioactive Material Shipment" requires that either one of
these two individuals certify prior to any shipment off site that the arti-
cles are properly classified, described, packaged, marked, and labeled
and are in proper condition for transportation according to DOT regulations.
4.
Regulatory Documents
The inspector verified that the licensae has current copies of applicable
NRC and DOT regulations so as to be able to comply with the requirements.
The licensee maintains a copy of 10 CFR from the U.S. Government Printing
Office, Superintendent of Documents, as part of a subscription service
that provides timely updated pages of 10 CFR.
The licensee also subscribes to the Federal Register and uses clippings
from the Federal Register to update the site copies of the annual editions
of 10 CFR and 49 CFR, which are purchased from the Government Printing
Office.
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Review of the above copies did not identify any omissions or overdue changes
to be made.
5.
Burial Site Requirements
According to a licensee representative the waste shipments that are planned
at this time are to the burial site in South Carolina. At the inspectork
request he was shown a copy of Chem-Nuclear's License No. 097 that was
issued by the State of South Carolina, and the inspector also reviewed a
copy of the burial site criteria.
The licensee has received notification of reductions being imposed by the
State of South Carolina on future shipments for burial, however, at the
time of the inspection there were no plans to ship elsewhere.
The licensee
representative stated that a waste reduction program is being carried out.
The inspector had no further questions on this item at this time.
6.
Procedures
The inspector verified that written approved procedures were available to
the individuals who solidify liquid radwaste, collect and compact dry rad-
waste, and transfer, package and transport low level radioactive material.
The licensee maintains an administrative procedure controlling the prepara-
tion review and authorization of operating procedures.
Except for temporary
procedural changes that do not deviate from the intent of the procedures,
the department, the Plant Operations and Review Committee, and the Plant
Superintendent sign off before a procedure is officially implemented or
changed.
The inspector noted that procedure no. OP 8301 which controls each authori-
zation to transfer or to transport low level radioactive materials incor-
porated the requirements of 10 CFR 30.41, 10 CFR 71, and 49 CFR 170-179,
and also the burial site criteria as described below.
Other procedures
are reviewed in paragraphs 8, 10, and 11.
7.
Implementation of Burial Site Recuirements
The inr1: tor reviewed the licensee's implementation of burial site require-
ments tollowing two reports of Yankee-Rowe radwaste shipment discrepancies
that were identified at the burial site.
Ofscrepancy report no. 8-79-1, August 2, 1979, stated that an approximately
2 ft by 3 ft wet contaminated area was identified on the floor of the trans-
port trailer on delivery of the load.
This trailer was a sole use vehicle.
The burial site survey identified up to 2 mres/hr, at contact, and 2,873
dpe/100 cm2 removable beta gamma contamination.
The applicable burial
site release criteria were 0.5 mrem /hr and 2,200 dpm/100 cm , and the trailer
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required decontamination before it was released.
The discrepancy report
did not state any apparent cause of the contamination.
The containers at
this position were 55 gallon drums of solidified liquid radwaste.
The licensee's corrective action included:
(1) Review, test, and modification of the solidification operation (see
Paragraph 10b).
(2) Provision to survey each radwaste transport vehicle on arrival at
the Yankee-Rowe site before it is loaded, so as to identify any radio-
active contamination present in the empty vehicle.
Discrepancy report no. 8-79-2, August 8,1979, identified the omission of
five drum lids in a shipment of 65 drums containing radwaste.
The licensee representative stated that the acceptability of the containers
would be verified before shipping any more drums without lids.
He stated
that each of the five drums contained an inner container set in concrete,
this concrete being nonradioactive.
Hangers used to support the inner
containers during the concrete pours interfered with the placement of lids
on these containers.
The other 60 drums contained radwaste solidified using
Portland cement, and lids were present on these drums.
The inspector noted that the above shipments were delivered prior to December
3, 1979, and that none of the containers was in excess of a Type A quantity
of radioactive material.
The licensee has taken corrective action to prevent
recurrence of the above discrepancies.
No items of noncompliance with NRC regulations were identified.
8.
Quality Assurance Program
Part of the inspection effort was to review the licensee's conduct of acti-
vities under the Quality Assuracce Program established, maintained and
executed with regard to transport packages so as to satisfy the require-
ments of 10 CFR 71.51 " Establishment and maintenance of a quality assurance
program".
The inspector reviewed the onsite copy of the NMSS Quality Assurance Pro-
gram Approval for Radwaste Packages No. 0068, applicable to Licenses OPR-3,
OPR-28 and DPR-36, dated May 4, 1979, and also the ensite copy of the Yankee
Atomic Electric Operational Quality Assurance Program (YOQA-1-A), as related
to radioactive material processing, packaging and transport.
The inspector noted that procedure AP 0209 Quality Control, in section
A.1, Requirements for Inspection states, in part:
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a.
Inspection of activities requiring Quality Assurance shall be performed
with approved written procedures which set forth the requirements,
acceptance levels, and specify the inspection responsibilities.
A
A
A
c.
Records
(1) Records shall be kept in sufficient detail to permit adequate
confirmation of the inspection program.
Review of licensee records identified only two recent logbook entries in-
volving radwaste packaging and transport.
One entry dated May 30, 1979,
indicated that the QA inspector inspected, on arrival, one of two Hittman
containers. The second entry, dated May 31, 1979 indicated tha'. the same
QA Engineer inspected resin pumping in progress, prior to shipment.
The
two containers were in excess of Type A quantities.
Shipping records for
these two containers are reviewed in Paragraph 12.
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The QA Engineer who made these logbcok entries had terminated and was not
contacted during the inspection.
No written procedure and no written in-
spection/ surveillance report was made available to the inspector which
identified the scope of these QA inspection activities.
The inspector noted that the QA Engineer apparently had conducted inspec-
tion activities with respect to the preparation of a container for trans-
port containing in excess of a Type A quantity of radioactive material
however there were no available written procedures and inspection / surveil-
lance reports which identified the scope of these inspection activities.
The inspector noted that additional information is necessary to determine
the licensee's compliance with the abcve requirements.
This is an unresolved
ites and will be reviewed again on a subsequent inspection.
(29/79-15-01)
9.
Audit of Shippino program
The licensee representative stated that an audit was performed on October 11,
1979, of the shipping program, hcwever, the report was not yet available
onsite.
The audit was conducted by YAEC Nuclear Services Division staff.
The licensee representatives stated that they had oral information that
the audit had identified a problem with training and also some items neces-
t
sary to satisfy recent changes in regulations and in burial site criteria.
The audit report will be reviewed on a subsequent routine inspection.
Further discussion of the audit appears in Paragraphs 10b and c.
The in-
spector had no further questions on this item at this time.
(29/79-15-02)
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10.
Training and Retraining
a.
Training Provided te the Plant Health Physicist and to the Technical
Assistant - Health Physics
The licensee reply dated September 25, 1979, to IE Bulletin No. 79-19,
stated:
"5,6 Training and periodic retraining covering NRC and 00T require-
ments, and applicable plant procedure requirements will be pro-
vided for all employees involved in the transfer, packaging and
transport of radioactive material.
This training will be per-
formed by January 1, 1980.
This training will include 1) the waste burial license require-
ments and 2) minimizing of low-level radioactive waste.
Records
of this training will be maintataed for future inspection by
NRC personnel."
A licensee representative stated that the Plant Health Physicist and
the Technical Assistant, Health Physics, had attended a two day course
on June 15 and 16, 1979, on 00T shipping requirements.
No training
was identified on minimizing of. low level radioactive waste.
No records of any other training, and no scheduled future training,
for any member of the Chemistry and Health Physics staff were iden-
tified involving these areas.
The licensee's completion of the above
training commitments will be reviewed on a subsequent routine inspection.
(29/79-15-02)
b.
Training and Retraining of Auxiliary Operators
Technical Specifications Section 6.4, " Training", states:
"6.4.1
A retraining and replacemert training program for the facility
staff shall be maintained under the direction of the Training Coordi-
nator and shall meet or exceed the requirements and recommendations
of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
Technical Specifications Section 6.10, " Record Retention", states:
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2
2
"6.10.2 The following records shall be retained for the duration of
the facility Operating i.icense:
g.
Records of training and qualification for current members of
the plant staff."
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Review of the training procedure, OP 2003, Attachments A and B, "Ini-
tial Training", item 9.
"Cooldown of bottoms, and drumming", showed
that Auxiliary Operators were trained to perform radioactive liquid
waste solidification.
The records included identification of the
training instructor, the demonstration instructor, and dates of satis-
factory completion 9f this training.
The Operations Supervisor's
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authorization signature is a prerequisite to an Auxiliary Operator
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standing watch at a station on completion of training to man the station.
The inspector noted that procedure AP 2003 Attachment C " Retraining"
did not specify any retraining on the above operations and there were
no written records of any retraining in these areas that were identified
to the inspector.
The Chemistry and Health Physics Supervisor stated that the procedure
for solidifying liquid waste (evaporator bottoms), No. OP 2381 Attach-
ment B " Drumming Evaporator Bottoms" was recently modified and he
had drummed with each crew within the preceding 60 days to verify that
the Auxiliary Operators understood and properly implemented the change.
No written record of this activity was identified.
The scope of this process change is indicated in Paragraph 11.
The inspector noted that it would be necessary to review the audit
report described in Paragroh 9, which was not yet available, to deter-
mine licensee compliance w th the above requirements.
This is an
unresolved ites, to be reviewed on a subsequent routine inspection.
'
(29/79-15-03)
c.
Other Retraining Provided to Chemistry and Health Physics Staff
ANSI N18.1-1971, Section 5.5 " Retraining and Replacement Training"
states in subsection 5.5.1 " Retraining":
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5. 5.1 Retraining
The retraining program should include:
1.
Plant startup and shutdown procedures;
2.
Normal plant operating conditions and procedures;
3.
Operational limitations, precautions, and set points;
4.
Emergency plans and security procedures;
5.
Abnormal operating procedures;
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6.
Emergency shutdown systems;
7.
Changes in equipment and operating procedures;
8.
General safety, first aid, and radiation safety;
9.
Alarms and instrumentation signals; and
10.
Operation of selected auxiliary systems important to overall
plant safety.
Procedure No. AP 9000, " Training of Chemistry and Health Physics Depart-
ment Personnel", specifies a two year cycle for retraining.
Review of retraining provided to Chemistry and Health Physics Staff did
not indicate that it was being conducted under the direction of the Training
Coordinator, and none of the technicians appeared to be scheduled to receive
formal retraining in eight items, nos. 1, 2, 3, 5, 6, 7, 9, and 10, of
the above list.
No records were identified to the inspector of any technician retraining
provided prior to 1979, however, these recoras were either misplaced or
lost and might still be retrieved.
Technician training records were pre-
viously reviewed on Inspection No. 29/78-08, paragraph 7, May 24-26, 1978.
There were available records of new employee training conducts.1 during
1978 and 1979.
No omissions were identified in new employee training records.
The inspector noted it would be necessary to review the report of the recent
audit and any subsequent corrective action to determine licensee compliance
with the above retraining requirements.
This is an unresolved item.
The
audit report and corrective action will be reviewed on a subsequent routine
inspection (29/79-15-04) to determine compliance with the above requirements.
11.
Inspection of Containers of Radwaste
The licensee representative stated that no shipment of radioactive mate-
rials was scheduled during this inspection.
The inspector selected two 55 gallon drums of radwaste from the estimated
75 drums that were ready for loading and shipment to the burial site.
At
the inspector's request the two drums were opened for examination of the
contents.
The contents were liquid waste evaporator bottoms that had been solidified
on-site using Portland cement and lime.
The addition of lime was a modi-
fication to the process used in solidifying the waste after notification
of the S.C. burial site discrepancy report, no. 8-79-1 described in Para-
graph 7.
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No liquid was evident in either drum.
The contents appeared to meet the
chemical / physical definition of a solid, however, the material could be
penetrated by the point of a stick held in one hand and appeared to be
friable.
12.
Review of Records of Shipments
Review of the records of the two shipments described in Paragraph 7 did
not identify any omissions of documentation specified in procedure no. OP
8301, " Radioactive Material Shipment".
No items of noncompliance with
NRC or DOT regulations were identified.
In addition, the inspector reviewed records of shipments on May 31 and
June 1,1979, in Hittman containers.
Documentation maintained on site
appeared to comply with the requirements of 10 CFR 71.62 " Records".
Letters
dated July 30, 1979 verified that YAEC had registered as a user of Cask
Models HN-200 and HN-600 (Certificates of Compliance 6574 and 9080).
The
packages of documents and drawings maintained on site appeared to comply
with the requirements of 10 CFR 71.12(b)(1)(i), and (2) for the use of
these cask models.
The licensee also maintained a copy of 1.he NMSS Quality
Assurance Program Approval for Radwaste Packages No. 0068, applicable to
Licenses OPR-3, DPR-28 and DPR-36 dated May 4, 1979.
Further description
of Quality Assurance documentation is given in Paragraph 8 whii:h identi-
fied an unresolved item.
The licensee rupresentative stated that no shipments involving containers
in excess of Type A quantities are planned at this time.
13.
Exit Intcrview
The inspector met with the licensee's representatives, denoted in Para-
graph 1, at the conclusion of the inspection, 4 p.m., December 14, 1979.
The radwaste burial site limits and the licensee's corrective actions fol-
lowing reports of radwaste shipment discrepancies that were identified at
the burial site were reviewed.