ML20003G452
| ML20003G452 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 03/19/1981 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20003G435 | List: |
| References | |
| 70-0820-81-03, 70-820-81-3, JAL, NUDOCS 8104290477 | |
| Download: ML20003G452 (18) | |
Text
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.D U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-820/81-03 Docket No.70-820
. License No. SNM-777 Priority 1
Category UR Licensee:
United Nuclear Corporation UNC Recovery Systems Wood River Junction, Rhode Island ~02894 Facility Name:
Fuel Recovery Operation Inspection at: Wood River Junction, Rhode Island Inspection conducted: M rch 2 4, 1981 Inspectors:
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W/ W. Kinnap, Proje Inspector datef signed Accompanying H. W. Crocker, Chief Person Fuel Facility Projects Section, PB#2 3//[/cf/
Approved by g s
H. W. Crocker, Chief date signed Fuel Facility Projects Section, PB#2 Inspection Sumary:
Inspection on March 2-4, 1981 (Report Number 70-820/81-03)
Areas Inspectec: Special announced inspection by a region-based inspector of l
the licensee's implementation of their licensed " Quality Assurance Program (OAP-004)
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for Preparation and Shipping of LSA Radioactive Materials".
The inspection involved 18 inspector-hours onsite by one NRC region-based inspector.
Results: No items of noncompliance or deviations were identified.
The licensee has taken appropriate actions to satisfy the October 1,1980, Imediate Action Letter, and, as far as the NRC is concerned, may resume routine shipments of waste to the l
Barnwell, South Carolina, burial site.
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DETAILS 1.
Persons Contacted
- R. J. Gregg, Plant Manager
- J. L'Heureux, Quality Assurance Manager J. O'Donnell, Nuclear Material Control Assistant The inspector also interviewed an operations upervisor, two operating technicians, and a quality assurance inspector during the course of the inspection.
- denotes personnel present at exit interview 2.
Background Information In late September 1980, UNC Recovery Systems sent four shipments of low specific activity (LSA) waste to the Beatty, Nevada, burial site which were rejected by the State of Nevada because leaking packages were found in two of the shipments.
The State of Nevada suspended UNC Recovery Systems' permit for use of the Beatty radioactive waste disposal site and required UNC Recovery Systems to return the waste to their Wood River Junction, Rhode Island, facility.
As a result of the above, UNC Recovery Systems made certain commitments to the NRC which were documented in an Immediate Action Letter dated October 1, 1980.
The licensee was to:
(1) assure that no radioactive material shipments would be made from your facility until management actions have been taken to prevent the presence of free standing liquids in packages for shipment and burial; (2) assure that the integrity of packages of waste for burial will not be lost during shipment; and (3) assure that shipments are not resumed until authorized by the burial sites, the origin and destination states, and the NRC, Region I.
This inspection was of the licensee's actions to provide these assurances.
The waste which presented the problems originated from the licensee's r
lagoons.
The licensee packaged raw, unprocessed, lagoon sludge in 55 gallon steel drums. The liquid in this waste separated from the solids. Some of the drums leaked during transit. The licensee also packaged lagoon liner material in wooden boxes.
Liquids also separated from the solids in some of the boxes.
Some of the boxes leaked during transit. These proble.ns were inspected in Inspection No. 70-820/80-19.
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3 The licensee also filtered-and packaged the filtered lagoon sludge in 55 gallon steel drums and in 4 by 4 by 4 foot wooden boxes. The licensee packaged thousands of drums and dozens of boxes of the filtered sludge. No evidence of separation of liquids from the solids was found in any of these packages.
The licensee is also decommissioning and decontaminating the processing facility.
Process waste, contaminated equipment, and decontamination waste are being removed from the. facility and packaged in 55 gallon steel drums and wooden boxes for shipment and burial.
No problems have been encountered with this waste during shipment.
Special inspections of the packaging of drums and boxes of this non-lagoon waste were made in December 1980 and January 1981. The inspectors ver-ified by observing the activities, inspecting the contents of selected packages, and observing the re-closure of the packages, that the packages contained no liquid waste and the packages were suitable for shipment and burial.
The licensee shipped this' waste to the Barnwell, South Carolina, burial site.
The licensee prepared a quality assurance program for the preparation and shipping of LSA radioactive materials. On January 26, 1981, Amendment ho. 15 to Special Nuclear Material License No. SNM-777 incorporated the licensee's " Quality Assurance Program (QAP-004) for Preparation and Shipping of LSA Radioactivo Materials" as an appendix to Section 200 of the licensee's approved license application.
Inspection of the implementation of this quality assurance program constituted a major portion of the inspection effort since adequate implementation of the program would constitute adequate completion of the actions outlined in the Immediate Action Letter of October 1, 1980.
3.
Imolementation of the Quality Assurance Program The inspector discussed Quality Assurance Program No. QAP-004 entitled, " Preparation and Shipping of LSA Radioactive Materials",
issued December 17, 1980, with the licensee. This quality assurance program addressed each criterion addressed in Appendix E, Quality Assurance Criteria for Shipping Packages for Radioactive Material, of 10 CFR 71, Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions.
a.
Organization The Manager of Quality Assurance reports to the Plant Manager as does the Manager of Operations.
The Manager of Quality
4 Assurance has the responsibility and authority to stop any work which is not in compliance with the Quality Assurance Program. Although authorized to do so, the Manager of Quality Assurance indicated that he has not delegated any aspects of the program to other organizations or individuals.
b.
Quality Assurance Program The quality assurance program is implemented by the use of written procedures.
The procedures pertinent to the preparation and shipping of LSA radioactive materials are given below.
Standard Operating Procedures S0P No. III-C, Revision II, Procedure for Packaging of Containers and Documenting Outgoing SNM Shipments, effective 1/3/80 Addendum to S0P III-C, Certain Requirements for the Preparation of Shipping Papers, effective 2/10/81 SOP No. III-H, Revision 0, Preparation of Radioactive Material Burial Shipments, effective 10/15/80 S0P No. X-N, Revision 0, Processing of Lagoon Solids for Disposal, effective 10/15/80 SOF' No. X-0, Revision 0, Packaging of Lagoon Waste, effective 10/15/80 SOP No. X-P, Revision 0, Packaging of Decontamination Waste, effective 11/7/80 S0P No. X-Q, Revision 1, Reinspection, Rework, and Preparation of Lagoon Waste Containers, effective 2/25/81 Quality Procedures QP No. 4.201, New, Procurement - Radioactive Material Shipping Containers, approved 1/3/80 QP No. 4.400, New, Receiving Inspection, approved 1/3/80 QP No. 5.411, Inspection of Radioactive Waste Packaging and Shipping, approved 10/30/80
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5 The licensee also uses checklists to document that the character-istics and attributes of the waste packaged and the packaging of the waste were satisfactory for shipment and burial.
These checklists include the following lists.
Burial Drums - Lagoon Press Material Container Specifi-cation and Inspection Report, no date Radioactive Material Burial Crate (7'x4'x4') Container Specification and Inspection Report, 11/7/80 Reinspected Burial Material Container Specification ar.d Inspection Report, 11/10/80 Radioactive Material Burial Shipment Container Inspection Checklist, no date Radioactive Material Burial Shipment Vehicle Inspection Checklist, no date Implementation of the above procedures and use of the above checklists are covered in another section of this report.
According to the Quality Assurance Manager, indoctrination and training of operating personnel and quality inspectors has been achieved by having these people participate in the preparation of the operating procedures.
This training has not been documented in any way. The inspector recommended that any training considered to satisfy the requirements of the Ouality Assurance Program be documented.
c.
Design Control The licensee uses 55 gallon drums which are DOT Specification 17H steel drums.
There is no design activities involved with these packages.
The licensee uses wooden boxes to package waste.
The licensee fabricates the 7 by 4 by 4 foot boxes.
Vendors fabricate the 4 by 4 by 4 foot boxes.
The Quality Assurance Program calls for Quality Assurance to review the box / crate designs to assure that they provide assurance that the regulatory shipping requirements will be met. The Quality Assurance Mana'ger had reviewed and approved the box designs given on drawings.
6 The inspectors observed to the Quality Assurance Manager that the drawings for the boxes did not specify some of the materials of construction in a way that a fabricator would know what materials should be used.
For instance, the drawing called for the use of " approved" caulking compounds to caulk the box joints. The drawing could and should specify the caulking compound to be used. The licensee indicated they would take appropriate actions concerning the specifications for the box / crate materials of construction.
d.
Procur'ement Control According to their Quality Assurance Program, the licensee uses procedures which assure that shipping containers are not procured without Quality Assurance review and input of quality requirements. According to the licensee, their quality procedure QP-4.201 entitled, " Procurement - Radioactive Material Shipping Container", dated January 3, 1980, is the procedure providing this assurance. According to this procedure, one might expect that the shipping containers purchased during 1980 for LSA radioactive waste material would have been procured following this procedure.
The " Scope" section states that the procedure is applicable to all procurement activities relative to radio-active material.
The inspector asked to see examples of the purchase orders for wooden boxes used to package the LSA radioactive waste.
The licensee showed the inspector an October 1980 purchase order for 80 wooden boxes from one fabricator-supplier and another October 1980 purchase order for 120 wooden boxes from another fabricator supplier. Neither of these purchase orders included a description of the QA requirements for the procurement attached to the purchase order as one would expect if QP-4.201 had been followed.
Instead, apparently in both instances the specifications for the boxes were prepared by the former Purchasing Manager, who was an engineer.
The inspector inquired as to the Quality Assurance involvement in assuring that the materials procured for the onsite fabrication of boxes met QA requirements. Again, at this time, there was no apparent involvement on the part of Quality Assurance.
The licensee indicated to the inspector that future imple-mentation of QAP-004, which was prepared in December 1980, will include Purchasing and Quality Assurance following QP-
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7 4.201 in the procurement and fabrication of wooden boxes for containing LSA radioactive waste for shipment and burial.
e.
Instructions, Procedures and Drawings The instruction, procedures, and drawings used in controlling the quality of pachaging and shipping'of LSA radioactive materials have been discussed previously in paragraphs 3.b and 3.c.
These instructions, procedures, and drawings were examined by the inspector.
The instructions and procedures include appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.
However, as discussed previously, the drawings for the wooden boxes do not include all the important specification for the materials of construction.
f.
Document Control The licensee's system for issuance of standard Operating Procedures and Quality Procedures is to include the approval of the Manager of Quality Assurance. According to the licensee, any change in procedures must be approved by Quality
- Assurance prior to implementation. Documents are to be available in the area where the activities are performed. A master list of the documerts and their latest revisions is to be maintained.
The inspector reviewed the procedures mentioned above and found that the Manager of Quality Assurance had approved all the procedures. The inspector found that the procedures being implemented at the time of the insp'ection were available at the work location.
The ic5 tactor found that the document master list included all the documents with the latest revision being listed.
g.
Control of purchased LSA Shipping Containers According to the Quality Assurance Program, the licensee controls purchased LSA shipping centainers primarily through a formal system of receiving inspecticas.
This system provides for inspection of incoming containers for compliance with purchase order requirements. Also, this system is to provide for the identification, segregation, and disposition of rejected items.
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Quality procedure QP-4.201, " Procurement Radioactive Material Shipping Containers", provides the first portion of this defined system.
This procedure calls for Quality Assurance to provide,the necessary Quality Assurance requirements for the shipping containers.
These requirements are to be provided in a form so that the requirements will be easily included in the formal purchase order.
Further, item 5.7 of QP-4.201 states the following.
"At the time of purchase requisition review, Quality Assurance will determine the need for receiving inspection or testing of the procured shipping containers, and state the requirement on the QA purchasing specification.
Upon receipt of the purchased items, QA will define the detailed receiving inspection requirements, and will perform or assist in the performance of the inspection.
(Reference QP-4.400)."
QP-4.400, " Receiving Inspection", dated January 3, 1980, provides the procedure and defines the responsibilities for the procedural steps in identifying, segregating, and disposing of rejected items.
h.
Identification and Control of LSA Shipping Containers S0P X-0, " Packaging of Lagoon Waste", effective 10/15/80, provides the procedure for packaging filtered lagoon sludge.
The section for drum preparation and the section for crate preparation both have instructions to apply a prenumbered
" Radioactive - LSA" sticker to the containers after the containers passed a previous inspection test.
S0P X-P, " Packaging of Decontamination Waste", dated 11/7/81, aise calls for the application of a prenumbered " Radioactive - LSA" sticker to the crate after it has been inspected.
SOP X-Q, "Reinspec-tion, Rework, and Preparation of Lagoon Waste Containers",
effective 2/25/81, is used for the reinspection, rework, and preparation of filtered lagoon waste which was packaged prior to implementation of S0P X-0.
This procedure calls for placing a prenumbered " Radioactive - LSA" label on the drums or crates over the old label on the container.
The number on the " Radioactive - LSA" label is used to identify the container and the records associated with the container.
Therefore, each container and its contents are traceable in the container preparation, inspection, and shipping records.
Quality Assurance maintains control of the prenumbered labels.
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9 1.
Control of Packaging and Shipping Processes The licensee depends on Standard Operating Procedures to
, control the processes.
Personnel performing the activities are to be trained in the use of the procedures.
.h.
Inspection The Quality Assurance Program states that an inspection program which verifies conformance of quality-affecting activities with requirements is established, documented, and accomplished in accordance with writters and controlled procedures. The procedures referred to in this statement are the Standard Operating Procedures, not separate inspection procedures.
According to QAP-004, "These procedures provide for in process verification of acceptability to Quality Assurance designated attributes, with sample overinspection by Quality Assurance personnel." S0P X-0, " Packaging of Lagoon Waste", requires that Container Specification and Inspection Report (CSIR) forms must be completed by the operators performing the inspection.
According to the licensee, the operator performing the work also performs the inspection while doing the work.
This operator then initials the CSIR form.
The procedure also states that the Quality Assurance Manager is responsible for monitoring adherence to the procedure.
This is accomplished by random inspection by Quality Assura'nce.
If a procedural
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step is inspected by Quality Assurance, the Quality Assurance ir.spector must note and sign the CSIR form to show that the step was inspected.
S0P X-P, " Packaging of Deconismination Waste", requires that Quality Assurance inspect the filled box prior to closure.
(The inspector noted to the licensee that the procedure does not specify that the container be closed immediately after this inspection to prevent the addition of more material after the QA inspection).
S0P X-P also requires that the operator performing and inspecting the work sign the CSIR form for the container. The Quality Assurance inspector must sign the CSIR form showing the final inspection before package closure wae performed.
S0P X-Q, " Reinspection, Rework, and Preparation of Lagoon Waste Containers" is essentially a quality assurance procedure. The purpose of this procedure is to assure that packages prepared before implementation of X-0 are acceptable for shipment and burial. Quality Assurance is required to inspect all rework performed under this procedure and to audit other procedural activities performed by Operations.
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10 k.
Test Control According to the Quality Assurance Program, when testing is used to verify packing and shipment acceptability, the licensee provides:
test procedures; testing of modifications, repairs, and replacements in accordance with original requirements or acceptable alternatives; and documented and evaluated test results.
Presently, the licensee is testing every containe r being reinspected under S0P X-Q, " Reinspection, Rework, and Preparation of Lagoon Waste Containers", for presence of liquids. According to step 5.1.2, "A moisture probe will be used on each container to ensure the absence of free standing liquid." The licensee has a procedure for using the moisture detector.
This procedure is an attachment to S0P X-Q and is entitled " Procedure for Using the Moisture Detector".
At the time of the inspection the results of the tests were not being documented. The licensee. indicated that the results of testing the containers for liquid would be documented on the CSIR form for tna container tested.
1.
Control of Measuring and Test Ecute=ent The Quality Assurance Program states that when measurement and testing of shipping packages are performed controls are used.
In the case of the moisture detector, prior to each use the detector is tested. The tip of the probe is placed in a pail of water. An audible buzzing sound must be heard indicating the probe senses water.
m.
Handling, Storage, and Shiccing The thrust of this criterion in Appendix E cf 10 CFR 70 is the protection of materials and equipment to be used in packaging by establishing measures to control the handling, storage, shipping, cleaning and preservation of the materials and equipment in order to prevent damage or deterioration. According to the licensee's Quality Assurance Program, special handling, preservation, storage, cleaning, packaging, and shipping requirements are established and accomplished by trained individuals in accordance with predetermined work and inspection instructions.
11 The licensee is storing wooden boxes to be used in packaging the LSA radioactive waste outside on the parking lot. The licensee has covered these boxes with plastic bags to provide some protection from exposure to the weather.
The licensee is storing empty unused drums outside on the ground.
The drums are positioned on their sides so that they will not fill with precipitation. The drums are not covered.
The licensee is storing the drums and boxes known to be filled with filtered lagoon sludge inside the heated warehouse.
These containers are the ones which may eventually be shipped to burial.
From the foregoing, one may surmise that the licensee is attempting to prevtit damage or deterioration of the packaging materials and equi ment. The means of instruction for accom-plishing this in t 4 past has been oral instructions and common sense on the part of the operating personnel.
Th2 licensee added cement and other absorbents to the bottom and top of the filtered sludge. The purpose of this cement was to absorb any water which might have become disassociated from the sludge.
The inspector asked the licensee how they established that the moisture present in the filtered sludge would not separate from the solids during transportation to the burial site.
The ifcensee explained that they have shipped thousands of drums of filtered waste to burial and there were no problems encountered with any of these containers during transport or at the burial site.
They also explained that they '1ad run some tests on the filtered sludge. On January 1981 a test was conducted on reducing the volume occupied by filtered lagcon solids by compaction using a waste compactor. A 32 percent reduction of volume of the material was realized. The compacted solids appeared to be more saturated with liquid than the original filtered sludge. A sample of this compacted sludge was vibrated on a syntron for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
There was no separation of the liquid from the solids. A moisture test showed the material was 57.06 percent moisture.
The foregoing experience and tests indicate that there should be no separation of liquids from the filtered sludge during transportation to the burial site. The above test results appear to satisfy conditions 29a-and 29b of the license, which were imposed by Amendn.crt No.15.
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Inspection, Test, and Ooerating Status According to the Quality Assurance _ Program r, acceptability status of packages can be readily determin. by the affected organizations.
Containers reinspected and_ reworked in accordance with 50P X-Q are well identified with reje :t labels if the containers do not meet the inspection criteria. After the container is reworked and the problem is corrected, this fact is documented on the reject tag.
The licensee is still considering how they will ult,imately mark the container as being accepted for shipment and burial.
Quality Assurance prenumbers and controls the prenumbered
" Radioactive LSA" labels. Operating personnel apply the reject labels according to the operating procedure.
According to the Manager of Quality Assurance there should be no operational bypasses of required inspections, tests, and other critical operations during the reinspection and rework activities.
The Quality Assurance Inspectors present during the reinspection and rework activities will assure that no operational bypasses take place.
If such an operational bypass is needed,the Quality Assurance Manager will have to approve it.
o.
Nonconforming Items According to the Quality Assurance Program, the licensee is to control nonconforming items until their acceptability is established and documented. The techniques used to provide this control are procedural controls, documentation, identifi-cation, and acceptance of rework and repair.
For the packages of filtered lagoon sludge, SOP X-Q defines the means of controlling the nonconforming packages. All packages except those prepared using 50P X-0 and have prenumbered
" Radioactive LSA" labels are considered to be nonconforming until they are reinspr,cted under 50P X-Q.
13 p.
Corrective Action The Quality Assurance Plan addresses the steps to be taken to correct conditions adverse to quality after the conditions have been discovered. The plan calls for corrective action evaluation, initiation of corrective action, and follow-up reviews.
In the case of the packaging of lagoon sludge, the licensee has evaluated the actions needed to correct the conditions adverse to quality which resulted in the shipment of raw sludge to Beatty, Nevada, in packages which were not strong tight packages.
The licensee has initiated the corrective actions with the preparation and implementation of this quality assurance program. The licensee must provide the follow up reviews of the implementation of this program to assure proper implementation of the program.
q.
Quality Assurance Records According to the Quality Assurance Program the licensee will produce and maintain sufficient records to provide documentory evidence of the quality and safety of items and the activities affecting quality and safety. The program calls for appropriate records to be produced and maintained. The program called for a list of the required records and their storage locations to be maintained with the records identifiable and retrievable.
During the inspection, the licensee prepared the list of records to be maintained and the storage location for these records.
r.
Audits The Quality Assurance Program calls for audits to be carried out to verify compliance with all aspects of the Quality Ass"- nce Progam and to determine the effectiveness of the program.
The audits will be performed by personnel not having direct responsibilities in the areas being audited. The audits will be performed in accordance with pre-established written procedures or checklists. Audit results will be documented.
Responsible management will take any necessary corrective actions. The audits will be performed at least annually.
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14 The Quality Assurance Program is just now being implemented; therefore, no audits have yet been performed.
4.
Implementation of Standard Operating Procedure XeQ The licensee has many drums and boxes filled with lagoon waste.
Some drums contain sludge which had been processed using the Parkson
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filter press.
Some of the drums contain raw sludge which was taken directly from the lagoons and loaded into the drums.
The licensee segregated the drums of waste as well as they could with the drums of filtered sludge being stored in the warehouse and the drums of raw sludge being stored in the outside " bull pan" area.
The licensee is using Standard Operating Procedure X-Q, Revision 1,
" Reinspection, Rework, and Preparation of Lagoon Waste", effective February 25, 1981, in determining the acceptability of drums of filtered lagoon waste for shipment and subsequent burial at either Barnwell, Toeth Carolina, or Beatty, Nevada, burial sites.
The inspector observed the Operations and Quality Assurance personnel as they reinspected and reworked some drums of lagoon sludge which had been processed through the Parkson filter press prior to the implementation of S0P X-N, " Processing of Lagoon Solids for Disposal",
and SOP X-0, " Packaging of Lagoon Waste", both of which were effective on October 15, 1980. The acceptability of the drums of filtered sludge processed and packaged after the implementation of S0P X-N and SOP X-0 is discussed in the next section of this report.
The licensee had copies of SOP X-Q, Authorization R0-300, and the Burial Container Reinspection Checklist at the warehouse work site.
In accordance with NIS Authorization No. R0-300, " Inspection of Drums in Warehouse" the licensee had marked off a work zone eight feet away from an array of containers containing higher quantities of special nuclear material than the LSA radioactive waste. The operators brought eight drums into the marked off zone.
This number of drums was wjthin the NIS Authorization limit.
The operators and ins'pector examined the bottoms of the drums for bungs as the drums were placed in the work zone.
The operators and inspector inspected the outside of the drums for cracks, holes, excessive rust, significant dents, uneven rims, and other defects which coe'd compromise package integrity. Any drum with a bung in the side was rejected.
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15 The operators opened the drums and inspected the condition of the lids and gaskets.
Solid lids with no bungs were placed on acceptable drums and lids with bungs were placed on reject drums while the inspector observed the operation.
If lids with bungs wera used on acceptable drums the bungs were to be luted to provide a seal between the bung and the bung hole.
This operation was not observed by the inspector.
The operators opened the plastic bag holding the filtered sludge.
The filtered sludge was inspected for the appearance of excessive wetness. The moisture probe was used to detect a free liquid in the bottom of the container..The operators followed the procedure for use of the probe. The probe was checked for operability before each use.
The components of the detector were cleaned and dried between each use.
The inspector observed these activities.
The operators and inspector observed whether or not the sludge was covered with cement.
Cement was added if needed.
The operator and inspector very carefully examined the plastic bag for tears or holes.
If holes or tears were present, they were repaired with cloth tape if possible.
The plastic bags were closed using a twisted " horse tail" and tape.
Excess space was filled with speadidry and the properly gasketed lid was replaced on the drum.
The operators filled out red reject tags which detailed any defect found in the container.
If the defect was corrected by rework this fact was so noted on the reject tag.
Both the operator and the quality assurance inspector initialled the tags.
l The operators and inspector filled out the Container Specification l
and Inspection Report form and placed a prenumber " Radioactive LSA" label on the accepted drums. The reject label on the rejected drums provided the only record of the rejected drums which gave the reason for rejection. The accepted drums were weighed and the gross weight was written on the " Radioactive LSA" label. The l
accepted drums were placed in a location in the warehouse reserved I
for accepted drums. The rejected drums were placed in a different location. According to the licensee, the contents of these drums would ultimately be placed in wooden boxes.
l The Container Specification and Inspection Report form did not include any information on the results of the moisture detector
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16 test for free standing liquid. After the inspector pointed out that this is an important characteristic as far as the burial grounds are concerned, the licensee agreed to record the results of the test for free liquid on the Container Specification and Report form.
The operators and inspector performing the work being observed by the inspector were very conscientious in the performance of the reinspection and rework activities.
The acceptability of the drums found to be acceptable appeared to be assured by their work.
The performance of the work was well documented on the reject labels and CSIR forms. Of the first 108 drums inspected 67 eventually were accepted after rework and 41 were rejected.
5.
Drums of Sludge Loaded Under SOP X-0' In mid October 1980, the licensee started using Standard Operating Procedure X-0, Revision 0, " Packaging of Lagoon Waste". This procedure called for appropriate quality assurance steps to be taken during the preparation of drums or boxes containing filtered lagoon sludge.
Step 5.1.4 called for Container Specification and Inspection Report (CSIR) forms to be completed by operations and Quality Assurance, as appropriate.
The licensee initiated the use of prenumbered " Radioactive LSA" stickers with SOP X-0.
The inspector reviewed the CSIR forms. These forms showed drums numbered 1001 through 1289. All of these forms were not filled out completely by the operators as called for in step 5.1.4.
Therefore, the documentation of the completion of the packaging and inspection steps is incomplete for some drums.
The licensee used an individual CSI3 form for each drum number 1290 through 1341. These forms appeared to have been completed satisfactorily.
The licensee indicated that in those instances in which the CSIR form was not completed at time of packaging the licen2- *ill I
complete the actions called for on the form and will so u.cument the completion of the actions on the CSIR form.
6.
Conclusion The inspector verified that in the main the licensee has satis-factorily implemented QAP-004, " Quality Assurance Program for Preparation and Shipping of LSA Radioactive Materials". As noted in this report, the licensee has indicated that they will take appropriate action to assure future compliance with all facete of l
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17 the quality assurance program including those facets where the inspector noted past weaknesses.
Based on the above findings, it is concluded that UNC Recovery Systems has taken appropriate actions to: (1) assure that no radioactive waste materials containing free liquid will be packaged for shipment and burial and (2) assure that the integrity of packages will not be lost during shipment and burial. Therefore, as far as the NRC is concerned, UNC Recovery Systems may resume routine waste shipments to the Barnwell, South Carolina, burial site.
The State of Nevada will not allow the licensee to resume shipments of waste to Beatty until the State of Nevada third party inspection program has been satisfied.
The licensee has been pursuing the completion of the inspection program with the State of Nevada.
7.
Exit Interview The inspector met with licensee representatives (denoted in paragraph
- 1) at the conclusion of the inspection on March 4, 1981. The inspector stated that as a result of the inspection it was concluded that in the main UNC Recovery Systems had satisfactorily imple-mented their " Quality Assurance Program for Preparation and Shipping of LSA Radioactive Materials".
Items in which past weaknesses were noted were discussed.
The fact that the drawings for the wooden boxes used for packaging LSA radioactive waste did not specify some of the materials of construction so that a fabricator would know what materials had to be used in fabricating the boxes was discussed. The licensee indicated they would take appropriate actions concerning the specifi-cations for the box materials of construction.
(Paragraph 3.c)
The fact that Quality Procedure QP-4.201 had not been followed completely in the past in the purchase of wooder. boxes and pruchase of materials for onsite fabrication of boxes in that Quality Assurance was not involved in specifying the quality assurance requirements for the boxes and material.
The licensee indicated that in the future Purchasing and Quality Assurance would follow QP-4.201 in the procurement and fabrication of wooden boxes for containing LSA radioactive waste for shipment and burial.
(Paragraph 3.d)
The fact that S0P X-P for packaging decontamination waste'does not require the container be closed immediately after the inspection by Quality Assurance was pointed out by the inspector.
The licensee m
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18 indicatt d they would take appropriate action to assure the containers are closed immediately so that additional waste could not be placed in the box after the quality assurance inspection.
(Paragraph 3.j)
The licensee gave the inspector a copy of the list of required quality assurance records and their storage locations.
(Paragraph 3.q)
The licensee stated that the audit of the Quality Assurance Program, which is to determine the degree of compliance by the licensee and the effectiveness of the program, will be performed by a person or persons independent of the performance of programmatic functions.
(Paragraph 3.r)
The fact that some of the Container Specification and Inspection Report forms for some of the drums packaged under SOP X-0 were not filled out completely by the operators was discussed.
The licensee indicated that in such cases the actions called for on the form will be completed and this fact documented on the forn.
(Paragraph 5)
The inspector noted that based on the licensee's present imple-mentation of their Quality Assurance Program and their commitments for action on aforementioned items it is concluded that UNC Recovery Systems has taken appropriate actions to satisfy the October 1, 1980, Immediate Action Letter. Therefore, as far as the NRC is concerned UNC Recovery Systems may resume routine waste shipments to the Barnwell, South Carolina, burial site.
(Paragraph 6) i i
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