ML20006D057

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Responds to SALP Rept for Aug 1988 - Oct 1989.Contrary to Info Contained in SALP Rept,Civil Penalty Not Assessed by State of Nv for Radioactive Matl Transport Violations.Issue Resolved W/State of Nv W/O Issuance of Civil Penalty
ML20006D057
Person / Time
Site: Waterford Entergy icon.png
Issue date: 02/02/1990
From: Dewease J
LOUISIANA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3P90-0652, W3P90-652, NUDOCS 9002120058
Download: ML20006D057 (6)
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. February:2, 1990~

l s U.S.' Nuclear Regulatory. Commission

. ATTN: Document Control Desk

( Washington, D.C.. 20555

- Subjects- Waterford Steam Electric Station - Unit' Number 3 Docket No. 50-382'_ _

Response to' SALP Report for the Period of-August 1,1988 through October 31, 1989  ;

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Gentlemen:

t The purpose of this ' letter is to respond to the Systematic Assessment of i Licensee Performance (SALP) Report for Waterford 3 for the; period of August 1, 1988 through October'31, 1989, which was-transmitted in the NRC letter f rom R.D. Martin ' to J.G. Dewease, dated. January 11,,1990. .

LP&L wishes to take this opportunity to express our appreciation for the

- professional and insightful evaluation of Waterford 3 performance pre- ,

sented in the_SALP report and'during our. January 25,-1990 management

-. meeting. We agree with the recommendations made in the SALP report and-are currently. working'towards their implementation. Please be aware that the management and staf f at Waterford- 3 are committed to making the plant a model facility for the industry. '

As discussed on January 25, we would like to provide clarification to

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' three items discussed in the SALP Radiological Controls performance

= analysis section. We believe that this additional'information was 4 largely unavailable to the SALP Board at the time the report'was

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written.

.The ifirst area of clarification involves reference to a violation due to skin exposures from hot particles. It should be noted that~the exposures, involving two individuals, occurred in May 1988 and were reported to the NRC in Waterford 3 Licensee Event Report 88-10, dated June 16, 1988. In that the exposures, the reporting of the exposures and~the' corrective actions occurred before the beginning of the SALP

' period (August 1, 1988), it'is requested that this violation not be a-consideration in the subject SALP period's rating.

I The second area that should be clarified involves missing data from the primary meteorological tower. The issue was originally identified in NRC Inspection Report 50-382/88-01, dated February 12, 1988, when i

the annual meteorological data recovery rate for 1987 was less than 9002120058 900202 An Entergy Company o

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[N 90. percent. -Since:then, our corrective actions have increased the overal1

' data recovery for the subject SALP period to greater'than 99 percent. .. On

i. some 'few occasions. when the data f rom the primary tower was unavailable, s ,

.the secondary tower. performed its backup function to maintain the high . .

I idata recovery rate'which greatly exceeds the regulatory requirements of

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90 percent.

The third area'of clarification involves the radioactive material transpor-tation violations issued by' the State of Nevada. Contrary to what was indicated in- the' SALP: report , a civil penalty was not assessed by Nevada for the violations. These violations were identified as Unresolved Item 382/8820 02 in NRC Inspection Report 50-382/88-20, dated August 24, 1988.

Corrective actions were taken'regarding the violations and the issue was

+ resolved ~ with 'the State of Nevada without the issuance of a civil penalty.

In:NRC Inspectio.n~ Report-50-382/88-30, dated February 8, 1989, Unresolved b

Item 382/8820-02 was closed. The Enclosure to this letter is the LP&L

' response .to NRC Inspection Report 88-20, which provides specifics of the transportation violations.and-their resolution.

The SALP rating assigned to Radiological Controls was a strong Category 2.

While it is unclear the extent' to which the above issues contributed to a I

" 2" rating:rather than a "1", we were encouraged by your suggestion on January 25 to submit clarifying information for reconsideration by the

, SALP Board. . We feel that the following information may also be useful

[ in your deliberations. i

1. Programa Recognized as Superior k '

At various times during the SALP rating period industry organizations,

' individuals and the NRC have recognized strengths in many aspects of our radiological control programs. These include:

o' Dosimetry Strengths - in all aspects including training, procedures, g qualification process, handling of computerized data -j 9 .o ALARA 3

Strengths - hot. spot tracking and flushing program, ALARA incentive program, ALARA committee meetings with management involvement, use of mock-ups, use of video / camera equipment, ,

computerized exposure tracking and alarm system I h

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.olInstrumenta' tion Calibrati~on'and Repair V ,. .. . .

, Strengths - computerized maintenance history,Leslibration history, f ' accountability, ' development of' a unique source ' check :

' device, in field usage,- low exposure, state of the= art h4' -

equipment 1

o~ Outage Planning and Facilities gg .. Strengths - appropriate prior _ training, appropriate phase-iniof g

contract' personnel, setting-goals, procuring-supplies-g ,

o- Leak Collection, Containment and Repair Program ii Uf ,

Strengths - rapid identification / containment / repair ,

2. Performan'ce Indicators "S4 . -

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Certain indicators provide objective measures of performance and the'

,y ability to compare performance across the industry._ Major radiological gj

  • _ control performance indicators and the Waterford 3'results are discussed below.

g o Collective Exposure.- From January ;1,1989 through ' September 15,2 1 .1989, the collective exposure:was less.than 20 man-rem. The collective exposure for the entireLyear of 1989 was 245-man-rem. Most

of the '1989 exposure occurred during the -

f all Refuel 3 ' outage, which _ involved modifications and steam generator _ work'in -j addition to: the refueling efforts. In 1988, .j another refueling: outage year, the' collective J

, exposure was 259 man-rem, where the industry. .

D: top' quartile was-262 man-rem. In 1987'the collective-exposure was 138 man-rem, but only a half-outage occurred in'that year.

3 The exposures indicate that the trend is ,

" improving. I

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t o Radwaste Volumes - Waterford 3 has demonstrated better than -'

industry average performance in radioactive waste generation. In 1989, 157 cubic meters was generated, where the industry median was 169 cubic meters. Since 1987 through 1989, the radioactive waste generation trend has been improving.

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pi si e  : o- Surface Contamination - Surface contamination was' maintained to N' , , less than 5% of' the RCA during the SALP -

period. - Of this, only l' to l}% of the Y' -

Y r accessible' area within the RCA was con-

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taminated.L This-is significant1y'less Q than the industryi goal of less.' than 10%

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p; J[ :o; Skin Contamination - - -

In 1987 during a half-outage year, there were - 142 cases ;L in 1988,' a full-outage E 1

" E year,.there were 277 cases. 'In 1989,-.

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, anotherifull-outage year,188 cases. From

% - January 1,1989 through September 15, .1989 1 (up to.the refueling outage) there were 7' < only 9 cases.

- o -- Uptakes of' Radioactivity' "Zero" cases during the ' SALP period.

Greater Than Industry F Report = Levels f3. : Program- Accomplishments During the SALP Period

o ' Evaluations of the Waterford 3 Radiological Controls programs

-by outside organizatione have attested to their superior ;u ef ficiency and ef fectiveness.  ;

o The National' Voluntary Laboratory Accreditation' Program s(NVLAP) evaluation of the Waterford 3 desimetry program during R the SALP period indicated that the program should be considered a model from which other organizations could learn.- It-was even-

< suggested that the Waterford13-dosimetry program supervisor become ,

^a NVLAP. evaluator. d i

k 01 Staf f members from other nuclear plants who visited Waterford 3 l

uere. impressed with the Radiological Controls Program and many requested assistance in improving their programs. 'l

'o. Industry sponsored organizations and technical societies have requested that members of the Waterford 3 Radiological Controls organization give presentations on various Waterford 3 programs because of their strengths. .

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EFor the reasons stated above and as discussed during the January 25, 1990 d

~SALP report management meeting, we are requesting that the Category 2 f 4.

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/Q t'rat'ingiin Radiological Controls be~ upgraded tola' Category l' rating. :1f '

' additionaljinformationJis required or should,you have any; questions 1 ~

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iVery!truly yours;1 ,

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ENCLOSURE

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POWER & LiGHTc NEW OaLEANS, LOUISIANA 70160 * ; (504)595 3100 UtTONlysM-October 10, 1988 4

W3P88-1919 I

, A4.05 QA B U.S. Nuclear Regulatory Commission  ;

-ATTN ' Document Control' Desk 4

. Washington, D.C. 20555 l I

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SUBJECT:

Waterford Steam Electric Station - Unit Number 3

-Docket Number 50-382 J NRC Inspection Report 88-20 Gentlemen:

Thel subject Inspection Report identified. unresolved item 8820-02 regarding .

transportation-related violations issued by the State of Nevada against low j level radioactive vaste shipments from Waterford 3 to the Beatty, Nevada  ;

- disposal - site .' -Messrs. D. Chaney and R. Baer, NRC Region IV, requested a letter summarizing the status of these violations lduring a conference call ,

on September 9,.1988. This~1etter responds =to their request.-

mLow level' radioactive waste shipment-numbers 88-1008 and 88-1009 arrived at the disposal site on May_31,1988'and June 3, 1988, respectively; 88-1010 and 88-10111both' arrived on June 6, 1988. These shipments.all arrived within'a one week period and are the shipments for which violations were

, issued. :The violations can'be summarized as follows:

'1. Manifests accompanying shipment numbers 88-1008, 1009, and 1011 each had an illegible copy attached; ,

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2. One of the placards on the front of the vehicle transporting shipment number 88-1008 was improperly displayed; and
3. Shipment number 88-1010 appeared to have shifted slightly during transport and a small hole was found on the front of one of the packages in the shipment.

'Another' violation had been issued against shipment number 88-1010, citing

~ discrepancies between package dose rates indicated on the manifest and those measured at the disposal site. This violation was rescinded, however, after Louisiana Power & Light Company (LP&L) contacted the disposal site Radiation Safety Officer and demonstrated that the violation could not have been issued against LP&L!s shipment.

"AN EGUAL OPPORTUNITY EMPLOYER"

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'W3P88-1919

-October 10, 1988 )

I LP&L instituted corrective actions, including procedura1' revisions and review of the violations, regulatory requirements and procedural revisions with personnel involved with radioactive _ waste shipments-in response to these violations. These actions were detailed in letters to the State of

. Nevada' dated July 5, 1988,. July 25, 1988,~ and August 4, 1988. The State of '

Nevada acknowledged LP&L's corrective actions in letters dated July 12 j 1988, August 1, 1988, and August 12, 1988; and provided clarification that '

LP&L could resume shipments to Beatty in a letter dated September 19, 1988.

LP&L feels that it has appropriately addressed'these violations, and based on correspondence from the State of-Nevada, considers these violations closed.

Messrs. Chaney and Baer indicated during the aforementioned conference call I that unresolved item 8820-02 could be closed based on documentation of resolution by the State of Nevada. Copies of all_ correspondence referenced in this letter, plus the letter rescinding the dose rate violation, and the letters citing the violations are attached for your review. These "

attachments comprise a complete package of all correspondence related-to the violations and document the fact that this-issue has been resolved with the State of Nevada, pending inspections of future shipments to Beatty to

-verify'that the corrective actions have been effective. LP&L therefore ,

requests that unresolved item 8820-02 be closed.

Specifics of the violations and corrective actions have not been reiterated in this letter as the information is fairly detailed and clearly presented in the attached correspondence.

Should you wish to discuss this matter further or require additional information, please contact Chadi D. Groome at (504) 595-2846.

Yo rs very truly.

N R. Burski '

M ager Nuclear Safety & Regulatory Affairs t

RFBtCDGlssf Attachments cc: 'E.L. Blake, W.M. Stevenson, J.A. Calvo, D.L. Wigginton, R.D. Martin, NRC Resident Inspector's Office (W3)

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.becs. J.C. Dewease, R.P. Barkhurst, T.F. Gerrets, F.J. Drummond S.A. Alleman, '

N.S. . Carns, D.F. Packer, P.V. Prasankumar, J.R. McGaha, K.R. Iyengari M.J. Meisner, G.E. Wuller, R.J. Murillo, G.E. Wilson, R.W. Prados, L.W. Laughlin,.S.S. DiJohn, W.T. Labonte, L'.R. Simon, C.E. DeDeaux,

' J.B. Houghtaling, G.W. Muench, R.T. Lally, Jr. .. W. A. Cross, R.P. O'Neill, W-3 Records Center, Administrative Support, Licensing Library '

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l[ State of NevadaJto LP&L - 8 letters. dated:  ;

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LJune.7,;1988 . ,

June 30, 1988 (3 letters)

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h., ~ , July 12, 1988 August 1, 1988 '

August'12, 1988 September: 19 - 1988- '

IC LP&L to State of Nevada - 3 letters dated: [

it E LJuly 5, 1988 July;25, 1988 August 4,.1988

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TCICHAA) H DRYAM - STATE OF NEVADA LAnntsct p warHil;

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Af m ennstraur -

c, ^ JEARY ORISPENTROG1

-e i Deneeeee JOSEPH Q JARVl%; M D ' ' i

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DEPARTMENT. OF HUMAN RESOURCES HEALTH DIVl810N Radiolockel Hoehh Secdon 4

505 East King Street Room 203 I

, Carson City, Nevada 89710-0 02) 885 5394 June 7,-1988

'J.M. Cain "

Louisiana Power and Light Company i 317 Baronne Street

.New Orleans, LA 70160- 1

Dear Mr.<Cain:

This letter.is in reference to Louisiana Power and Light Company LLW shipment no.;88-1008 which arrived at the Beatty, NV disposal site on May 31, 1988 under Nevada Site User Permit No. Q446. ,

Inspection findings revealed the following violations:

1

1. ool-Q446-4-1  !

U.S. Department of Transportation regulation 49 CFR 172.516(c)(4) requires each placard to- be -located away from any 3 marking, such as advertising, that could substantially reduce its effectiveness,.and-in any case, at least:3 inches (76.0 mm.) away from such markings..

Contrary to this requirement, the placard located on'the front of I the transport. Vehicle was located within three (3) inches of a i

license' plate holder which-was displaying four license plates.

The' top of - the placard was also wrapped over the top of the vehicle bumper which should be prevented on future shipments.-

The entire placard must. remain completely visible.

2. 001-Q446-4 49. -CFR -172.201(a)(2) states that the required shipping description on a shipping paper and all copies thereof use for transportation purposes, must-be legible and printed (manually or mechanically ) in English.

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- 2COntrcry -to this rcquircmsnt, tho - corrior copy of. tho shipping

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' manifest furnished - with the shipmenti had several:- portions which r

C wereJnot, clearly-legible. The violation appears to be ' a result J

.of. an.-improper printer. font' or inadequate pressure on-.thes -

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LYoulare required"to. advise this office in writing within 20 days:

of your receipt of this letter to indicate the~ actions that'will ,[

be taken to correct these violations, when the: corrective actions  :

will be implemented-and-the methods that will be taken to prevent recurrence of the violations.

Sincerely, ll ,.

h' . IhhA.

e Stani -R. . Marshall, Supervisor- i Radiological Health Section -

, Bureau of Regulatory Health Services

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Enclosure

-11w\lplevioltr- ,

cc ': . Bill Spell, State of Louisiana

. Virgil Autry, State of-. South Carolina .

Earl Ingersoll, State of Washington As, / /< .' .

Jack Hornor, Region V, NRC Bert Gray, Nevada Health Division

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k 'T IMPROPERLY DISPLAYED PLACARD

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STATE OF NEVADA Lawatsct. p w4tntw:

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HEALTH DIVIllON :

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505 Eas: King Street Roosa 203 Carson City, Nevada 89710' (702) 885 5394

-June 30, 1988 '

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LLouisiana Power and Light Company 317 Baronne Street )'

New Orleans, LA '70160 RE : 003-Q446-2-1:

003-Q446-3-1 1 003-Q446-3-2 -

Dear Mr. Cain:

Thisiletter is . in reference to the Louisiana ^ Power and Light Company LLW shipment number 88-1010 which arrived at the Beatty 4

' site i on , June 6, 1988. The shipment' was made -:under Nevada ~ Site '

User. Permit. No. -Q446 issued- to . Louisiana Power and ' Light '

Company, Waterford 3 SES.

Inspection findings revealed the following v'iolations:

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.1. - 003-Q446-2-l' a .+

'U.S. -Department. of . Transportation regulation 49 CFR 173.425(b)(1) requires = materials to beipackaged in strong, tight

. packages-;so that there will be no-leakage or radioactive material under. conditions normally incident to transportation.

Contrary to'this requirement, package number 88-0111.was found to .

have-'a hole' in ~the front of the package. The hole was l approximately 1/4 inch-in diameter and was located 20 inches from D the.left-side and 20 inches from the bottom of the package. No K

loss of container contents was-found as a result of the hole in

the package l-
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49 ' CFR _'17 3 ' 42 5 ( b)( 6 ) requires the shipment.to be braced so as to

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transportation.

,l 49'CFR 173.448(a) requires each shipment of radioactive material i

.to be secured- in order to prevent shifting during normal transportation conditions. -l '

Contrary to these requirements, the containers were found to have shifted to the front of the trailer as a result of the wooden 1

~ wedges being' released from between the containers during transit. 1 The release of.the wedges created approximately 6 inches of space- )

between the rear floor bracing materials and the rear packages. "

3. 003-Q446-3-2 ,

l Nevada Administrative Code 459.823(2) requires the manifest to -l contain a statement which is as complete as is practicable and J includes a physical description of the waste, its volume, the l identity and quantity of radionuclides, the total radioactivity and the: principal enemical form.

Contrary to this requirement, three packages were found to .

have-external radiation levels significantly different than the radiation levels indicated on the shipping manifest. The three 1 packages,- the indicated levels and_ measured radiation levels i are as follows:

l package No. Indicated rad. level Measured rad. level 0111 800.0 mR/hr 550.0'mR/hr 0049 60.0 mR/hr 100.0 mR/hr 0047 80.0 mR/hr 110.0 mR/hr Mr. Larry Simon from your company was present during confirmation of the findings above.

You .are required to advise this office in writing within 20 days of your receipt of this letter of the actions that will l i

be taken to correct the violations, when the corrective l actions will be implemented and the methods that will be used to prevent recurrence of the violations.

Upon receipt of the corrective actions, we will review the resp,onse and advise you concerning resuming shipments to the l Beatty site.

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.Sta y R. Marshall, -Supervisor:

-Radiological Health-Section

, Bureau of Regulatory Health Services-e, llw2\lplcitr ss l n 'ect. Bert Gray, Nevada Health-Division j J F

Virgil;Autry,-State of South Carolina l

. Earl:Ingersoll, State of. Washington  :

Jack' Horner,, Region V, NRC l Bill Spell, State ofl Louisiana l Novelle Tucker,:.U;S. DOT j '

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CICHA33 -H. SIIVAN ? STATE OF NEVADA '. "

LAWRENCE P 4 AIMEll -

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JSARY ORIEPENTROG 1 JOSEPH QJ JA%vil; M O.

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DEPARTMENT OF HUMAN RESOURCES 1 HEALTM Divist0N

' Radtelegical Ms;rt Secesse-l K 505 East Klag Street. Room 203 - 4 h .

Caroom City, Nevada 89710 '

, (702) 405 5394 = .;

-June 30, 1988 i q

J. M.-Cain- 7 L

ELouisiana Power and Light Company '

=317 Baronne. Street-New Orleans,'LA 70160 t

lRE:' 002-Q446-4-2 .

Dear Mr.-Cain:

@ This L ; letter is in reference to the Louisiana . Power and Light' i l -Company LLW: shipment number- 88-1009 which arrived at the Beatty

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. sits c on ; June 3,.1988. The shipment had been made under . Nevada

. site User Permit No. Q446 issued to Louisiana Power and Light

. Company, Waterford 3 SES.

Inspection findings revealed the following violation:

'1. . -002-Q446-4-2

- U.S.- . : Department of Transportation -regulation 49; CFR 172. 201( a) ( 2 ) requires' the shipping description 'on: a shipping

? pappr: and all copies thereof used forr transportation: purposes, to L( be legible and-printed-(manually or mechanically) in English.

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Contrary; to this- requirement, the carrier copy.of the shipping manifest af . with tho ' Louisiana Power and Light Company shipment n 1009 was not legible. This appears to'have

- been caused the printing style of the manifest printer.

You 'are requeueF tcr ' advise this office within 20 days .of your

,'.. receipt .of' this - letter of the actions that will be taken - to correct the- violation, when the corrective actions will be

. implemented and the methods to prevent recurrence of the

- violation.

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.. iffl youfhave any: ' questions. please. feel free to contact- me. _

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., , StafrTay : R.~ Marshall, Supervisor '

F iRadiological Health Section .

Bureau of Regulatory, Health Services ,

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Lec:l Bert Gray,' Nevada Health Division  !

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Jack Hornor, Region.V,.NRC 3 VirgilLAutry, State of South Carolina

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-Earl Ingersoll, State of Washington e . Bill Spell,. State of Louisiana

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  • DEPARTMENT OF. HUMAN RESOURCES '

. M*,Al.TH OtVillON .

N 0a n.4i.e.ess.: M inn s n '

N$' 505 East King Street. Rooni 263 -

ijg 4 3 Caroom City, Nevada ' 89710 (703) 335 5394

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June 30,~.1988 .,

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'J; M..Cain' Louisiana Power and Light Company 1 1

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4 317 Baronne Street 1

,1. , New orleans,.LA ,70160 t

n p 4, 9' RE: 004-Q446-4-3 Ji

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Dear Mr. Cain:

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  • ' This letter is Jn reference to the Louisiana Power and Light Company L LLW shipmimt number 88-1011 ' which arrive at ; the Beatty -

f . site on June 6, 1968. The shipment had been ~made- under Nevada 4 i '

Site. UseriPermit ? No. .Q446 issued to Louisiana Power ' and Light  !

l Company, Waterford 3 SES.  !

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.-Inspection findings revealed the following violation:

N 1. U.S.. ' Department. of ' Transportation regulation. 49 CFR n 172.201(a)(2) requires; the shipping' description on~ a shipping -

p , paper-and;all copies thereof used for. transportation, purposes, to p.- be. legible-and printed'(manually or mechanically) in English.

t Contrary to this requirement, the carrier copy of the manifest i

- could not - be read. This appears to have been caused iby the printing style of'the manifest printer.

s T You? are reqpired to advise - this office within 20 days of your

. receipt : of. this . letter of the actions that will be taken to

, correct the : violation, when the corrective actions will be Limplemented and the -methods to prevent recurrence of the 1l . violation, pl ' , iingerely, e f l i

$ a y R. Marshall, Supervisor -

P' Radiological Health Section b -Bureau of Regulatory Health Services '

JUL 6 1988 m

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' ec t : Bert Gray, Nevada Health Division.

Jack Nornor,' Region---V. NRC

. Virgil.-Autry,' State of-South:C4rolina Earl Ingersoll,- State of Wash #gton Bill. Spell,. state of Louisiana Novelle Tucker,'U.S. DOT O

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DEPARTMENT OF HUMAN RESOURCES utrL1n OwsMon nesset ei ne.ien heu n SC Ee .t King $tteet. Room 203 atoon City. Nevede 49710 (702) 885 5394 July 12, 1988 R. n Burski, Manager Nuclear Safety and Regulatory Affairs Louisiana Power and Light Company P.O. Box 60340 Mail Unit N-17

, New Orleans, LA '70160 Dear Mr. Burski 1

.:Your letter dated July 5, 1988 is acknowledged. The letter describes the actions that have been taken to correct the violations' documented during our recent inspection of Louisiana

-Power and. Light Company LLW shipment number 88-1008.

The corrective actions will be reviewed during future inspections.

You are requested to respond to the violation letters concerning shipment numbers 88-1009, 88-1010 and E8-1011 prior to resuming shipments-to the Beatty site.

If you have any questions, please feel free to contact this office.;

. h ately, t d y R. Marshall, Supervisor Racao Sgical. Health Section Burasu of megulauory Laith Services cc: Bert Gray, Nevada ~ Health Division Bill Spell, State of Louisiana Virgil Autry, State of South Carolina Earl ~Ingersoll, State of Washington Jack Hornor, Region V, NRC Novelle Tucker, U.S. Dept. of Transportation

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, . DEPARTMENT OF HUMAN RESOURCES 9,LALFN 9tvl60001 s.naseems me.no eem SOS test Klog Se,oet. Reede $44 '.,

ca e enty. Nevede ettto August 1, 1988 (708) 886 4294 R. F. Burski, Manager Nuclear safety and Regulatory Affairs Louisiana Power & Light 317 Baronne street New Orleans, LA 70160 -

RE: 002-044(-4-2 004-0446-4-3 Dear Mr. Burski Your letter dated July 25, 1988 is acknowledged. The letter describes the actions that have been or will be taken to correct the violations documented during recent inspections of LLW shipments from Louisiana power & Light.

4 The corrective actions will be reviewed during future inspections to determine their effectiveness. We are still awaiting a response to our letter dated June 30, 1988 concerning your LLW shipment number 44-1010.

Upon' receipt of the response, we will consider reinstatement of

. permission to ship to the Beatty site.

If you have -any guastions, please feel free to contact me.

incerely, l

& ' hY*

ha y R. Marshall, supervisor i

Radiological Health section Bureau of Regulatory Health services lw2\1p10F A  !

cc: Bert Gray, Nevada Health Division

  • Jack Hornor, Region V. NRC '

Virgil Autry, state of south carolina Earl Ingersoll, State of Washington Bill Spell, state of Louisiana Novelle Tucker, U.S. Dept. of Transportation o

SEP 15 '96 14: 16 PAGE.002

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DEPARTMENT OF HUMAN RESOURCES HEALTH Divitt0N Aedeologesel Meelet 6er:6ee l 505 East King Seteet. Room 203 {

Careen Cley Neude 89710 (708) 848 8394 August 12, 1988

)

l R. F. Burski, Manager 1 Nuclear Safety & Regulatory Affairs  :

Louisiana Power & Light- i 317 Baronne Street i New Orleans, LA" 70160  !

RE: 003-Q446-2-1, 003-Q446-3-1

Dear Mr. Burski:

Your letter dated August 4, 1988 is acknowledged.

The letter  !

described actions that will be taken to correct the violations documented during the recent inspection of LLW shipment no. 88- ,

1010 from Louisiana Power & Light. The corrective actions were in response to violation numbers 003-Q446-2-1 and 003-Q446-3-1 cited in our letter dated June 30, 1988.  :

J The corrective actions will be reviewed during future inspections to determine'their effectiveness.  :

If you have any' questions, please feel free to contact me.

Sincerely, I

a m y R. Marshall, Supervisor ,

l Radiological Health Section  !

p Bureau of Regulatory Health Services lw2\lplvioltr l-cc: Bert Gray, Nevada Health Division L ' Earl Ingersoll, State of Washington 7 L Virgil Autry, State of South Carolina

' i Novelle Tucker, U.S. Dept. of Transportation i Bill Spell, State of Louisiana '

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' .AtWWitTRATIVE SUPPORT . i L DEPARTMENT OF HUMAN RESOUltCES' .

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e september 19, 1988 I

Chadi oroome  !

Louisiana Power and Light company P.O. Som 80340

,' Mail Unit N-17 New Orleans, LA 70180 ,

Dear Ms. Groome l t

i  ;

This letter' is in response to the request irom your management  :

concerning Permit No. LLW shiposats to the teatty, NV site under Nevada site User -I 9446 issued to Louisiana Power and Light Company.

Your letters dated July 5,1988, July 25,1988 and August 4, 1988 I to this office shipments described to the Beatty site. the corrective actions for recent LLW Our letters dated July 12,.1988 Au et  ;

it and August 13,1988 advised that the oorrective actions w,oul be

.and reviewed during iuture inspections' of shipments ~ from Louisiana Power Light company.

I regret that our review of.the corrective actions

  • and acknowledgments in writing were not interpreted by your management to include permission to resume shipments to the Beatty site. ,

You are advised that Louisiana Power and Light Company is permitted to resume LLW shipments to the saatty site. -

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If you have any further questions, please feel free to contact me. i sincerely, j

72 -  :

stan f R. Mar $'all, Supervisor Radiological ,. '-h section .

Bureau of Regulat:.- "calth Services l iw2\1pigrmelte i

cci Bert Gray, Nevada Health Division Virgil Autry, State of South Carolina Earl Ingersoll, state of Washington sill spell, state of Louisiana 4

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9 SEP as 'es 12:21 '"'

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PQWE A & LiGHTU181ANA / sir70160 NEW ORLEANS. LoulSIANA saRoNNestaist

. (604)$95 3100 NNMM .}

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i July $. 1988 W3P88-1631 A4.06 i QA l 1

Mr. Stanley R.. Marshall Department of Human Resources Health Division ]

Radiological Health Section l '

$0$ East Kint Street, Room 203 l

Carson City, Nevada 98710

]

SUBJECT:

Waterford Steae Electric Station - Unit Number 3 i Nevada Radioactive Waste Disposal Site User's Permit .

Number Q446 '

Low Level Weste Shipment Number 88-1004 )

REFERENCE:

Department of Human Resources Letter from l Stanley R. Marshall to J.M. Cain dated June 7, 1988 I

Dear.Mr. Marshall:

i Louisiana Power & Light Company (LP&L) is in receipt of the referenced letter indicating that two transportation-related violations were issued i against LP&L's low level waste shipment number 88-1008. This shipment ,

arrived at the Beatty, Nevada disposal site on May 31, 1988. The refer- i enced. letter was received on June 14, 1988, and requires a. response within 20 days of receipt. As is discussed in detail below, LP&L has ,

reviewed the violations and has initiated corrective actions to prevent '

their recurrence. )

Violation number 001-Q446-4-1 indicates that the placard on the front of I the- transport vehicle was placed within three (3) inches of the license plate holder, and therefore not in conformance with the requirements of i

49CFR172.516(c)(4). Photographic documentation was included in the  !

referenced letter to substantiate this finding. l Violation number 001-Q446-4-2 indicates that several portions of the t carrier copy of the shipping manifest were not clearly legible, . and ,

t l

l "AN SOUAL OppORTUNffY EASM. OYER" i

i l

Pass 2 W3P88-1631 July 5, 1988 l

j therefore violated the requirements of 49CTR172.201(a)(2). This regu-lation specifies that: .

l The required shipping description on a shipping paper and all copies thereof used for transportation purposes, must be legible and printed (sanually or mechanically) i in English.

l LP&L was aware prior to the shipment leaving Waterford 3 that the carrier  !

copy of the manifest was not entirely legible, and took what it considers appropriate compensatory action. The manifest required by the disposal site is a five part carbon form, the last copy of which generally does not print clearly. As LP&L has been doing for quite some time, the first page of the manifest was photocopied and designated as the carrier copy I in lieu of the. last page of the five part manifest. In fact, both the j State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned .

them about resolving the legibility concern. To avoid future confusion l regarding which copies are used for transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest.

Radwaste Department Technical Procedure number RW-2-501, " Radioactive ,

Waste Shipments" provides instructions regarding Department of Transpor- '

tation,= Nuclear Regulatory Coenission and disposal site requirements for L radioactive waste shipments. The procedure requires completion of .

checklists to insure that the proper paperwork and notifications have  !

been completed, and that the shipments and transport vehicles meet the i applicable. regulations prior to leaving Waterford 3. In light of these violations, the procedure has been reviewed, and is being revised to be '

more specific with regard to both placarding and shipping paper legibil- i ity requirements. Approval of the changes is espected within the next j two weeks, but in any case will be received prior to the next radioactive waste shipment. In addition, these violations and applicable regulatory requirements have been reviewed with personnel involved with radioactive waste skipennte. '

To insure timely responses, please address future correspondence to me.

My address ist P.O. Boa 60340 L Mail Unit N-17 New Orleans, Louisiana 70160 t

- - . . . . - ~ . . .

Pag) 3 i '*

  • i W3P88 1631' '

July 5.-1968 -

.i I

Should you require additional information regarding these violations, i please contact Ms. Chadi D. Groome at (504)595-2846. I Very truly yours, .l r

, $. ..i i R.F. Burski Nuclear Safety & Regulatory Affairs Manager ,

RFB/C384sy cci J.G. Dewease, R.P. Berkliurst, N.S. Carns, P.V. Prasankumar, W.T. LaRonti, L.R. Simon, D.B. Stevens, N.J. Meisner, G.E. Wilson, W.H. Spell,

.V. Autry, E. Ingersoll, J. Horner, B. Gray, Waterford 3 Records Center, ,

Administrative Support (1), Licensing Library '

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PQWER & tiGHTUlSIANA NEW oateANS. LoutStANA / siriAaoN~e 70160 * (504)596sracer 3100 f NSN EsM '

~ .j July 25, 1988  !

W3P88-1623 i A4.06

.QA  ;

Mr. Stanley R. Marshall '

Department of Human Resources '

Health Division I Radiological Health Section 505 East King Street, Room 203 i

Carson City, Nevada 98710 l

SUBJECT:

Waterford Steam Electric Station - Unit Number 3 Nevada Radioactive Waste Disposal Site User's Permit .

Number Q446 Low Level Waste Shipment Numbers'88-1009 and 88-1011

REFERENCES:

(1) State of Nevada Department of Human Resources Letter from .

Gtanley R. Marshall to J.M. Cain dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Waste Shipment Number 88-1009 (2) State of Nevada Department of Human Resources Letter from  !

Stanley R. Marshall to J.M. Cain dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Waste Shipment Number 88-1011  ;

(3) Louisiana Power & Light company Letter W3P88-1631 from R.F. Burski to Stanley R. Marshall dated July 5,'1988 (4) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to R.F. Burski dated July 12, 1988

Dear Mr. Marshall:

,: Louisiana Power & Light Company (LP&L) is in receipt of references 1 and 2 which describe transportation-related violations issued against LP&L's low level waste shipment numbers 88-1009 and 88-1011 which arrived at the Beatty, Nevada disposal site on June 3, 1988 and June 6, 1988, respectively. As both i

violations are the same, they are being addressed together in this letter.

Also, we would like to note that these violations are the same as violation l

number 001-446-4-2, for which corrective action has been initiated, as described in reference 3 and acknowledged in reference 4.

"AN SOUAL OPPORTUNffY ER4PLOYER" t

. _ _ .__._r___________________..___________.__ . _ _ _ . . _ . . . . . _ . . _ _ _ . . _ _ _ - . . . _ , _ _ _ . _ . . _ , _ _ _ . . _ . _ . . . . _ _

h utatu .

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. July 25, 198g

)

)

These two violations indicate that several portions of the carrier copy of I the shipping manifests were not clearly legible, and therefore violated the t requirements of 49CFR172.201(a)(2). This regulatica specifies that:

The required shipping description on a shipping paper and all copies thereof used for transe:rtation purposes, must be {

i legible and printed (manually mechanically) in English. -

LP&L was aware prior to the shipments leaving Waterford 3 that the carrier copies of the manifests were not entirely legible, and took what it considers  :

appropriate compensatory action. The manifest required by the disposal site  !

is a five part carbon form, the last copy of which generally does not print  ;

clearly. As LP&L has been doing for quite some time, the first page of the  ;

manifest was photocopied and designated as the carrier copy in lieu of the  !

last page of the five part manifest. In fact, both the State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned thee about resolving the legi- ,

bility concern. To avoid future confusion regarding which copies are used for transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest.

Radweste Department Technical Procedure number RW-2-501, " Radioactive Waste Shipments" provides instructions regarding Department of Transportation, Nuclear Regulatory Coenission and disposal site requirements for radioactive waste shipments. The procedure requires completion of checklists to insure

[

that the proper paperwork and notifications have been completed, and that the shipments and transport vehicles meet the applicable regulations prior to leaving Waterford 3. In light of these violations, the procedure has been ,

revised to be more specific with regard to shipping paper legibility require-ments. In addition, these violations and applicable regulatory requirements have been reviewed with personnel involved with radioactive waste shipments.

Should you require additional information regarding these violations, please contact Ms. Chadi D. Groome at (504)595-2346.

Very traly yours, \

) '

R.F. Burski Nuclear Safety & Regulatory Affairn Manager RFB M $sy ec: J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankusar, W.T. LaBonte, L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autry, E. Ingersoll, J. Nornor, B. Gray, N. Tucker, Waterford 3 Records Center, Administrative Support (1), Licensing Library sw t~ s- -e w,e ~m w m- rvm-,-m- o- -v e ,,- -- ~I

... w ln 1 Louissama POWEM & LiGH T / m.

.o~~ tra.1 . o .ex.0u0 NEW ORLEANS. LOU 18tANA 70100 + (604) 596 3100  ;

UtT8kkIONeU ' i August 4,1988 W3P88-1630 ]

A4.06 '

QA i

Mr. Stanley R. Marshall Department of Human Resources

.)

's Health Division Radiological Health Section- ]

505 East KinC Street', Room 203 3 Carson City, Nevada 98710 1

SUBJECT:

Waterford Steam Electric Station - Osit Number 3  ;;

Nevada Radioactive Waste Disposal Sito User's Pesuit Weber.Q446 .

c Low Level *deste skisment number 88-1010

REFERENCES:

(1) State of Nevada Department of Human Resources Letter froa l Stanley R. Marshall to J.M. Cain dated June 30, 1988 .:

Regarding Louisiana Power & Light Company Low Level Waste Shipment Number 88-1010 (2) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to Chadi Groome dated July 18, 1988 ,

Dear Mr. Marshall -  ;

Louisiana Power & Light Company (LP6L) is in receipt of the referenced letters '

i discussing transportation-related violations issued against LP&L's low level waste shipment number 88-1010. This shipment arrived at the Beatty, Nevada

, disposal site on June 6, 1984. .As is discussed in detail below, LP&L has >

l reviewed the violations and has initiated corrective actions to prevent their recurrence.

Violation number 003-446-2-1 indicates that ccatrary to 49CFR173.425(b)(1), l which requires that " Materials must be packaged in strong, tight packages so-that there will be no leakage of radioactive material under conditions normally incident to transportation", package number 84-0111 was found to have a hole approximately % inch in diameter on the front of the package.

The violation continues that "No loss of container contents was found as ,

a result of the hole in the package." While LP6L is not minimising the seri- )

ousness of a breach of integrity in a shipping package, it is important to i note that this small hole did not result in leakage of radioactive material, j and therefore the package met the intent of the cited regulation.

l "AN BOUAL Opp 0RTUNffY EMPLOYER" l 1

r As a result of this violation. LP&L has taken several steps to insure the integrity of its shipping packages. Packages already on site were reinspected.

Radwaste Department Technical Procedure numbers RW-2-501, " Radioactive Waste '

Shipments", and RW 2-300, " Receipt. Storage and Loading of Shipping Contain-ers", have been revised to clarify acceptance criteria and focus both receipt and final (prior to shipment) inspections on box integrity. Furthermore, while not a regulatory requirement for this type of container, procurement specifications have been upgraded to Quality Class II which imposes more stringent controls on both the vendor and LP&L.

Violation number 003-Q446-3-1 indicates that the subject shipment did not meet the requirements of 49CFR173.425(b)(6) and 49CFR173.448(a) in that "the containers were found to have shifted to the front of the trailer as a result of the wooden wedges being released from between the containers during transit.  :

The release of the wedges created approximately 6 inches of space between ~

the rear floor bracing materials and the rear packages." The cited regula-tions specify, respectively '

Shipment must be braced so as to prevent shifting of lading under conditions normally incident to transportation.

and Each shipment of radioactive materials shall be secured I in order to prevent shifting during normal transportation conditions.

In response to this violation LP&L has thoroughly reviewed its loading practices and discussed the incident with personnel involved with radioactive I waste shipments. Extreme care was taken in preparing this shipment for transportation. The methods employed to secure the boxes should have been adequate to prevent the cargo from shifting to any appreciable degree, and an explanation of the loading procedures is in order at this time. The ship- i ment consisted of ten boxes. The boxes were centered in the trailer, one behind the other, with the first box placed flush against the front wall of the trailer, and each subsequent box abutting the box in front of it.

(Because the boxes bow slightly when full, the tops of the boxes could not be placed squarely against each other.) Two by fours were nailed to the floor of the trailer around each box to keep the boxes in place during transit. ,

A restraining device (a metal bar and ratchet mechanism) secured to the sides >

of the trailer (approximately three-fourths up from the bottom of the box) was installed behind the fourth box to further inhibit movement and another was installed behind the last box to keep the cargo from moving backward toward the trailer doors. In addition, cargo straps were strung from side -

to side in the trailer behind every other box. Because the boxes were slightly bowed and the tops could not abut, wooden wedges were driven between the ,

boxes to further maintain the existing spacing and provide shock absorption.

,a- .. .

,'a

  • Page 3 '

W3P84 1630-3 i

f Apparently some of these wedges vibrated free and gave the appearance that -

the load may have shifted. As the wedges were not necessary to secure the shipment, they will not be used for future shipments. ,

As reference 2 rescinded violation number 003-Q446 3-2, the third violation '

cited in reference 1, this violation does not require a response. However. --

LP&L wishes to point out that its efforts in investigating the violation identified the differences between the information presented in the viola-tion and LP&L's documentation for the subject shipment. These differences were confirmed by the U.S. Ecology Site Radiation Safety Officer during a telephone call with LP&L personnel. The violation cites discrepancies between radiation levels meaaured at the disposal site and those indicated on the shipping manifest for three boxes. Two box numbers, 047 end 049, do not matet. any box numbers on LP&L's manifest. The third box number, 0111, was indicated on the manifest. However, the viciation specifies that the manifest indicated a radiation level of 800 mR/hr for this box, while the highast radiation level of any . bon in the subject shipment was 500 mR/hr ,

contact. As the documentation clearly indicates, these radiation level dis- ,

crepancies could not have been cited against the subject shipment, and LPkL appreciates your letter rescinding this violation.

Should you require additional information regarding these violations, please '

contact Ms. Chadi D. Crooms at (504) 595-2846.

Yours very truly, R.F. Burski Manager ,

Nuclear Safety & Regulatory Affaire RFB/CDGIpla cc J.G. Dewease R.P. Barkhurst, N.S. Carns, P.V. Prasankumar. W.T. LaBonte, '

J. Ridge 1, L.E. Simon D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autry,'E. Ingersoll, J. Hornor, B. Cray, N. Tucker, Waterford 3 Records Center. Administrative Support Licensing Library

, . DOCUMENTATION OF TELEPHONE C0teWNICATIONS l

DATEt September 9, 1988 TIME: 1000 A.M. R5K.

B.C. Morrison, C.D. Croome PARTY CALLINGt J.A. Ridget. L.R. Simon / LP&L I (Name) p (Company)

]

H.D. Chaney l PARTY ANSWERINGt R.E. Baer NRC. Renton IV i (Name) (Company) 1 i

$UBJECT: IR 48-20 FILET A7.09 QA l 2

J 1

1 1

.- l SLMIARY: (INCLUDING DECISIONS AND/OR C019ENTS) )

l Chadi discussed the Nevada violations and indicated that all items had been taken care of. The NRC.vants & summary of the problems and resolutions in a formal letter. l Chaney addressed the training response required by IR 88-20. He wants us to formally j document our commitment to IEB 79-19 items 5 and 6 and how we are going to keep t the Radwaste Training up-to-date.

L l

ACTION REQUIRED:

l l

Chadi.will submit a letter on Nevada questions. Barbara and Marty Langan will prepare response to training question.

DISTRIBUTION: Records Center. Administrative Support, Licensing Library, Site Licensing Support File

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  • UNitt0 ST Afts NUCLEAR C:ECULATORY e .:

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f ceti:N av ett nVAN PLARA DalVS. RITC $d0

\..... AnuwofoN taxAs ).m hl$ 2 4 M RECEIVED (f In Reply Refer To: r_ ADMNSTRATIVE SUPPORT Docket: 50-382/88-20 .

SEP 1 IMS

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Louisiana Power & Light Company ILN:

' '7 ATTN: J. G. Dewease, Senior Vice President .

Nuclear Operations  ;

.317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:

This refers to the inspection conducted by Mr. H. D. Chaney of this office during the period July 10-15, 1988, of activities authorized by NRC Operating License NPF-38 for the Waterford Steam Electric Station Unit 3, and.to the discussion of our findings with Mr. N. Carns and other members of your staff at ,

the conclusion of the inspection. '

Areas examined during the inspection included transportation of radicactive materials and low-level solid radioactive waste management. Within these areas, '

the inspection consisted of selective examination of procedures and representativa records, interviews with personnel, and observations by the NRC inspector. The inspection findings are documented in the enclosed inspection report.

Within the scope of the inspection, no violations or deviations were identified.

However, we are concerned about the inactivity of your training program for radioactive waste (radwaste) workers and personnel involved in radioactive -

material transportation activities.

Accordingly, you are requested to respond, in writing, within 30 days of the date of this letter, outlining steps taken to ensure that initial training and ,

retraining programs are fully implemented for personnel in the onsite radwaste group that sat'sfies NRC Inspection and Enforcement tulletin 79-19 commitments and current industry practices. Your response should address the root causes of why the previously established program was allowed to become inactive, and the short and long tem actions to be taken to improve and maintain the training program in the future.

One unresolved item is identified in paragraph 8 of the enclosed inspection -

report. ,

The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Papemork Reduction Act of 1980, PL 96-511.

IOM M . _ _ __ _ _ _ . _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _

'I qJ n

)

. '. Louisiana Power & Light' Company -

2-Should you have any questions concerning this inspection, we will be pleased to ,

discuss them with you. -

Sincerely, , l f

f L.U lang, d 4 / L. J. Callan, Director Division of Reactor Projects 1

Enclosure:

I; Appendix - NRC Inspection Report  ;

50-382/88-20 i cc w/ enclosure: *  !

Lcuisiana Power & Light Cospany ATTN: G. E. Waller, Onsite ,

Licensing Coordinator , l P.O. Box 8

-Killona, Louisiana 70066 ,

Louisiana Power & Light Cospany ATTN: N. S. Carns, Plant Manager i

P.O. Box 8 Killona, Louisiana 70066

. Middle South Services '

7 ATTN: Mr. R. T. Lally P.O. Box 61000 New Orle4ns, Louisiana 70161 ,

Louisiana Power & Light Company ATTN: R. F. Surski, Acting Manager '

Nuclear Safety and Regulatory Affairs 317 Baronne Street ,

)

P.O. Box 60 H0 New Orleans Louisiana 70160 J 1

Louisiana Radiation Control Program Director l 4

a 4 en I

1

-*w, -~ - . - - - - . , - . ._,_m_..-. ,-., m _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _

APPENDIX i U.S. NUCLEAR REGULATORY COMMISSION REGION IV l

NRC Inspection Report: 50-382/88-20 Operating License: NPF-38 Docket: 50-382 j

Licensee: Louisiana Power & Light Company (LP&L)  ;

317 Baronne Street i New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (WAT-3) i Inspection At: WAT-3 site, Taft, St. Charles Parish, Louisiana Inspection Conducteti: July 10-15, 1988 j l i

!aspector: " 1' 7. 8 IY f H. D. Ct. ark?)ladiationTpe*'cyalist, Facilities Ett I Radiologic.a1 Protection Se#: tion i l

Approved: . dS47 d d5 R.G . Baer, Chief, Facilities Radiological Date Protection Section I

Inspection Summary Inspection Conducted July 10-15. 1988 (Report 50-382/88-20)

L Areas Inspected: Routine, unannounced inspection of transportation of  !

, radioactive materials and low level radioactive waste (LLRW) management. l Results: Wittiin the areas inspected, no violations or deviations were identified. One unresolved item concerning the transportation of radioactive materials was identified (see paragraph 8).

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OETAILS

1. Persons Contacted .

LP&L

  • N. Carns, Plant Manager
  • S. Alleman, Quality Assurance l

Manager j F. Davis, Nuclear Operations Support and Assessment Engineer -

G. Espenan, Nuclear Operations Support and Assessment Engineer l R. Kenning, Nuclear Operatiens Support and Assessment Engineer  ;

  • W. LaBonte Radiation Protection Superintendent  !

J. Ladet, Security Supervisor, Operations

  • M. Langan Technical Support Training Supervisor '

O. Landeche, Health Physica (MP) Supervisor .i it. Marler, HP Trainer .

R. McLendon, Oostmetry Supervisor ,

  • P. Prasankumar, Assistant Plant Manager, Plant Technical dervices '

S. Ramty, Assistant Radiation Protection Superintendent  :

"J. Ridge 1, Assistant Reliation Protectiori Superintendent

  • D. Stevens, Radweste Supervisor l

Others *

  • T. Staker, NRC Resident Inspector
  • Denotes attendance at the exit interview. j The NRC inspector also contacted other licensee personnel including administrative, security, and quality assurance (QA) personnel.
2. NRC Inspector Observations l

The following are observations that the NRC inspector discussed with the licensee during the exit interview on July 15, 1988 and (observation b.

which was discussed with R. Kenning) by phone on July 19, 1988. These observations are not violations, deviations, unresolved items, or open items. These observations were identified for licensee consideration for -

program improvement, but the observations have no specific regulatory

requirement. The licensee stated that the observations would be reviewed  ;

l (no toamitment was made in regard to observation b.). .  ;

L , a. Clean Waste Release - The procedure currently in use for the testing of gamma scintillation counting of bulk paper and plastic wastes to be released for unrestricted use is not signed or dated.

l

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b. Redwoste Program Assessments - Neither the Corporate Nuclear Support  !'

Serv'ces section nor the onsite Operations Support and Assessment Group routinely performs assessments on low-level solid radwaste'and '

transportation activities. ,

l

3. Open Item Identified During This Inspection '

An open item is a matter that requires further review and evaluation by the NRC inspector. Open items are used to document, track, and ensure adequate follow-up on matters of concern to the NRC inspector. The '

following open item was identified: '

Open Item Tjifje See Paragraph .

382/0820-01 Retraining of Radweste Staff 6 l

4. UnresolvedItes!@ntifiedDurinoThisInspectig ,

l An unresolved item is a natter about which more information is required to ascertain whether it is an ecceptable ites, e daviati e , or a violat hn The following unresc1ved itan was identified:

Op3n,, hem Title jpe3 Paragraph l- 382/G820 02 State of Nevada Identified a Tranrportations Regulation Violations

5. Ornanization and Manacement Controls - Transportation /Radweste (83522/83722)

' The NRC inspector inspected the licensee's staff assignments including:

organization, assignment of responsibilities, authorities, staffing, identification and correction of problems, audits and surveillances, j communication to employees, documentation and implementation relating to .'

radioactive effluents and solid wastes, and the transportation of  !

radioactive materials to determine adherence to commitments contained in Sections 11 and 13 of the Updated Final Safety Analysis Report (UFSAR),

and NRC Inspection and Enforcement Bulletin (IEB) 79-19 and compliance with Technical Specification (TS) 6.2, 6.8, and 6.13.

The NRC inspector reviewed the organization of the licensee's radwaste department which is responsible for management of solid radioactive waste processing and transportation of radioactive materials (RAM). The NRC -

inspector also reviewed the LP&L Corporate support (Nuclear Support l ' Services Section) provided the WAT-3 radweste program. -

The NRC inspector reviewed the licensee's senior management policies

, (Nuclear Operations Management Manual), which included the assignment of responsibility for RAM shipments, implementing procedures for control of LLRW processing and transportation of RAN, the NRC approved Process .

L I.

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i

Control Program (PCP) (Procedure RW-01-210), field quality control .

activities, and the NRC approved QA program (Docket: 71-0604) for i transportation activities. The licensee utilizes an ancillary speciai  !

scope QA program in conjunction with their 10 CFR Part 50, Appendix 8, QA .

program for ensuring quality in RAM transportation activities. Procedures i and other documents reviewed during the inspection are listed in the  ;

Attachment to this report. l 1

The NRC inspector reviewed the licensee's audit program including current i and planned audits for LLRW and RAM transportation e-tivities. The  ;

. following audits and surveillances were reviewed:  !

Surveillance QS-8IP055, Purchase Orders and Receipt Inspection of i Shipping Packages ,

Audit $A-87-024.1, Radwaste Processing i

  • Audit SA-87-003E.1, Radweste Training and Qualification 1
  • Audit A39.356-87.1, Container Products Corporation (Vendor Audit)

The licensee's audits were found to be comprehensive and included an i adequate amount of perfomance based o'ojectives. The NRC inspector noted that while the Nuclear Operations Support or4 Assessment (NOSA) Group '

perfomed operational assessments on most other activities at WAT-3, N0SA i does not perform assessments in the area of radweste operations. ,

No violations or deviations were identified,  !

6. Trainino and Qualification - Transoortation/Radweste (83523/83723)

The NRC inspector reviewed the licensee's training. program including '

adequacy of training, employee knowledge, qualification requirements, position descriptions, technician, contract technician screening and training, audits, and training not covered by INP0 accreditation to determine agreement with comm'teents in Section 13.2.2.8 of the UFSAR, .

, and NRC IES 79-19, and compliance with the requirements of Technical l Specification (TS) 6.3 and 6.4.

The NRC inspector observed work practices and interviewed radweste group personnel. The licensee's biennial requalification program for personnel involved in radweste processing and transportation activities was reviewed for adequacy. Training records for the plant staff (approximately .

21 radweste and HP individuals) involved in the processing and transportation of RAM were reviewed for completeness. The NRC inspector also reviewed the licensee's implementing procedures and lesson plans for the training of radwaste personnel. The NRC inspector noted (this was also identified during a QA audit) that at least four radwaste personnel have not received any formal radweste training since hiring on at WAT-3.

None of these persons appeared to have performed radwaste processing activities other than collection of waste. The last training for many 9

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5  !

l radweste personnel was the completion of on-the-job training checklists in 1986. The NRC inspector noted that the licensee had provided many  !

individuals with required reading of procedural changes and vendor. '

provided training on radweste and transportation activities in 1986 and l 1987 which satisfies the biennial requalification requirements. The NRC, ,

inspector also noted that the lesson plans for the radweste training program were not current (1984 vintage) in the areas of regulatory <

requirements and licensee facilities. The licensee training program for radweste workers was an item of concern in NRC Inspection i Report 50-382/85-26 and resulted in the issuance of a Notice of Violation (NOV) for the failure to er.sure.that a contract worker received proper training. This area was 9trengthened as a result of the NOV. The Nuclear Training Department (NTO) staff positions responsible for radwaste  ;

group training activities have had a high turnover rate in the past which has resulted in the program not being maintained in a current status. The  ;

licensee's NTD had filled the vacant position of instructor for the ~

radwaste group around July 1, 1968. The licensee's radweste training -l program will be considered an open item pending licensee implementation of  !

an upgraded training and requalification program for redweste workers  :

(382/8820-01). '

No violations cr deviations wue iden'cified, I l

7, '

Solid Radioactive Weste (84522/_34127)

The NRC inspecter reviewed the licensee's program for the control, classification, charactarization, and shipment of low-level radioactive  ;

waste to determine agreement with the commitments ccitained in Section 11 of the UFSAR and compliance with the requirements contained in TS 3.11.3,  :

4.11.3; 10 CFR Parts 20.301, 20.311, 61.55, and 61.56; and the J recommendations of NRC Branch Technical Position (BTP) papers on LLW classification and waste fom.

l The NRC inspector reviewed the licensee's computerized program for I management of waste processing and packaging activities (RADMAN). The licensee's biannual evaluation of waste streams and development of isotope J correlation factors were reviewed. The licensee's LLW characterization i and classification program is well documented. The NRC inspector reviewed I the licensee's vendor provided processes for dowatering of filters and resins. The licensee's PCP and the licensee's venoor's PCP for the processing of various waste streams were reviewed for management control l over changes and revisions. The NRC inspector reviewed selected records of waste processing activities (resin solidification, filter dowatering, dry active waste compaction, and oil solidification) for 1987. j l

The NRC inspector reviewed the licensee's records for LLW shipped since 1 1985. The following tabulation shows the total volume of LLW shipped for the 1985 through 1987.

. - . . ,%. - ~ . , _ - _ . _ . _ _ _ . . , _ . . , _ _ _ , . ,

, kw ' + (O

, c' s  !

l Volume Shipped (Cubic feet)

Year Goal Actual Curie Content l

1985 5,000 9,997 33.5 1986 6.227 6,138 37.5 1987 8,000 13.530* 178.2 t

  • Included approximately 5,000 cubic feet of boric acid concentrator bottoms held over from 1985 due to licensee efforts in evaluating onsite burial. ,

No violations or deviations were identified.

8. Transportation (86721/86740)

The NRC inspector reviewed the licensee's program for transportation of RAM, program audits, procurement and evaluation of packaging, i determination of package activity, preparation of packages for shipment,  !

maintenance of packages, delivery of packages to carrier, and the receipt -

i of RAM for compliance with the requirements cf 10 CFR Parts 20.205 and -

20.311; 10 CFR Part 71; anc Department of Transportation (DOT) regulations (49 CFR) incorporated by 10 CFR Part 71. <

l The NRC inspecter reviewed 30 shipping records frort the 11;86 and 1987 l period for completeness and accuracy. The licensee's authorization to utilize specific shfpping packages was verified. The NRC -irspector reviewed the documentation including advstcod notif' cation, package

' opening and closing checklists, hazardogs waste manifests, sole use g instructions..and survey recores. The NRC inspteto? ncted that the ,

L licensee routinely used extensive checklists for accomplishing shipments "

j of RAM.

The NRC inspector was informed, on July 11, 1988, by the licensee, that LP&L had been notified by the state of Nevada that several violations of '

00T and burial site requirements had be identified during inspection of l two of the licensee's waste shipments to the Beatty, Nevada, burial site ',

'(May 1988, Radioactive Shipment Record (RSR) 88-1008 and June 1988, R$R 88-1010). The violations identified by the state of Nevada included radiation dose rates on waste containers significantly greater than shipping records indicated, a waste container (strong tight package for low-specific-activity shipment (s)] was found to have a h-inch hole in it (manufacturing defect), improper location of 00T required placard, illegible man'fest copies, and the bracing used in a sole-use enclosed trailer-van came loose and allowed the load to shift. The licensee,had not-fully investigated each of the apparent violations at the time of this inspection. The licensee had instituted an immediate inspection of waste containers used for the shipment of dry active waste (DAW). The licensee detemined that several of the onsite ready for use Container Product Corporation's B-25 containers (steel boxes of approximately 95 cubic feet capacity) contained manufacturing defects. These containers are not required to be DOT approved or NRC certified. The hole in the B-25 L

__1 __________ _ _ _ _ _ . _ . . . _ . , . _ _ . _ _ _ . _ . . _ _ - , _ _ . _ _ . _ . _ _ _ _

% .- . j

. . . , 7 i container, found by the state of Nevada, was the result of a weld '

burn-through that was painted over at the manufacturing facility and was  ;

not readily identifiable during the licensee's proceduralized preuse 'l inspection of the container. At the time of this NRC inspection, the licensee had 'aiready instituted corrective actions concerning potential - i defects in waste containers used for DAW packaging and had revised their i receipt inspection program for strong, tight containers of all eakes. The r licensee informed the NRC inspector by telephone on July 18, 1988, that .

preliminary . investigation of the apparent high dose rates on waste i containers may be the result of a state of Nevada mix up involving another ,

shipper's material and not LP&L's. NRC enforcement will be deferred until  !

all of the state of Nevada's violations have been resolved. The  !

licensee's apparent violation of NRC and D0T regulations will be  :

considered an unresolved item pending further review by the NRC during a future inspection (382/8820-02). ,

t The NRC inspector noted that the licensee's QA department had just f completed a surveillance of waste packaging procurement and receipt {

inspection. The draft results of the surveillance indicated that several ,

deficiencies were identified in the licensen's program for these l eeterials.  ;

The licenru han not expeM5nced any tras;ortation incidents which E caused a redation in the effectivenus of an NRC or 00T curtified packagireg stwa the previous inspection, j

, No violations or deviatior.s were identified.  ;

l '

l, 9. Review of Periodic and Special Recorts (90713) l L I The NRC inspector reviewed the licensee's semiannual effluent reports for 1986 through 1987 for compliance with the requirements of TS 6.9.1.8, 6.13, and 6.15 and the recommendations of RG 1.21. .

The licensee's semiannual reports for the years 1985, 1986, and 1987 were ,

reviewed and compared to the licensee's documentation concerning  ;

radioactive material shipments (solid LLRW disposal), PCP changes, and modifications to the solid LLRW processing systems.

No violak. ions or deviations were identified, t

10. Exit, Interview 4

The NRC inspector met with the NRC resident inspector and licensee-representatives denoted in paragraph 1 on July 15, 1988, and summarized the scope and findings of the inspection as presented in this report. The licensee agreed to provide the NRC with all correspondence involving the state of Nevada's 1988 inspection and enforcement actions concerning LP&L.

l l

,, _ . _ . . , , _ _ . . . - ~ . . . . _ . . ~ . - . , _ . _ _ _ . . _ - . . _ . , _ _ . , _ _ , . . . _ . _ _ _ _ _ _ _ _ __ ___

~ .._. _ _ . -_ _ __

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J o' a' T..G HML l41 ,

19 I4b t.' INSFECTION REF0F1 i

.* , So- s es-Ou D.D.CPtKN11 EKVLEW.EP l IIILE. EgylflQU peTE l,

' Nde l f tC .UPPC4 t 1909 Dpyf gemgn) ,Mgopal, dcction Yl. Spectal Scope Quality Folicies Chepter 5. Radi oacti ve Waste Managemeent 3 10-01-07 i i

Flaut.0catettpon_Meeuet i Volume 20. Radioactive Waste Manecement Pr ocedur es

?

RW-01-100 Radioactive Waste Reduction 2 18-97 FW-01-200.= Record Freparacion. Filing.  ;

and Storage 1 06-26-87 ,

RW-01-210. Process Control Program 2 07-10 i RW-02-100. Waste Material Collection and , j y Hand 11no 4 03-25-88  :

DM-02-110. Waste Ramole Collection and Isotope Evaluation 3 05-19-87  :

RW-02-120.' Handling used Protective Clothing 0 07-14-8/, t i

EW-02-200. Packaging-R4dicactive Solid Waste p (DAW) for Disposal 5 08-20-86  !

.RW-02-210. Radioactive Waste Solidification 6 10-26-87 RW-02-200. Radweste Filter Disposal 2 v1-07-B6 ,

"RW-C2-230, Waste Mstorial Segregation 3 06-20-8B ,

RW-02-331, Granulating Material f or Disposal 2 03-29-E8 L RW-02 "40, Blewoown Dominera11rer Resin '

i Transfer 0 04-07-G5 L RW-02-3OO. Receipts Storage and Loading of ,

Shippino-Containers _ 2 05-23-96 i RW-02-310 Storage of Loaded Shipping Containers 3 09-15-86 RW-02-320. Packaged Radioactive Weste Control and Inventory 5 06-06-87 ,

RW-02-330 Radioactive Waste Tracking 1 02-18-86  ;

RW-02-401,-Use of Redman Operating Program 0 08-27-87  ;

RW-02-411, Use of Redman Data Manager 0 . 09-10-87 RW-02-420, Operation of the Filtrk Computer Program 0 05-04-87 RW-02-430, Operation of the RAMSHP Computer Program 1 06-01-88 RW-02-500, Radioactive Material Shipment 3 .09-15-87 RW-02-501, Radioactive Waste Shipment 1 04-08-88 RW-02-521. Type and Quantity Determination 0 05-05-87 RW-02-530.. Decay Heat Calculations for USNRC Certified Containers 0 05-05-87 RW-02-541, Hydrogen Gas Calcul ation 0 05-04-87 i 02-19-86 l RW-02-800. Dose to Curie Conversion 1 02-18-86 i RW-01-B10. Waste Classification. 1

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g .. 4 %'r , dor. f e,me coin yg ~ l l-[ . F1-013. LN-Technoloongu Froctus Control *

=Frocram for Dewst era no Liners G Uni neur. ,55-001. t.N Technolooies Frocess Conteul Frocram for Radwust e Solidificat ion R 05-05-87 l 35-o05. Oreer a t i nu Fror.edure for LN

' Technolooies Radwaste Solidt f a cation ,

ti Sssta.o #S908 - ~G Uianowr.

NRC Appr oved TODical Feport PS-53-0378. j '

NUS Radwaste Solidification System -

05-70-85 NUC19tC.IC*iO109.QCQtCAmgat_Ergqpyytys j i

"NTC-037. Radweste Services Training Frogram 2 04-09-85 j p LV%f90_ Elf 0F ,

TO:0-000-01. Radweste Helper Final Exam 1 01-23-86 l T001-000-01. Radweste Helper'- Redweste  !

Frogram Overview 1 ,

09-28-34  !

T001-001-00, Radweste Helper - Nuclear I

. Power Orientation 0 09-08-84 i T007-002-00, Radweste Helper - WAT43 Radweste 4 ,

Systen;s .

0 .09-08-L4 ,

'T002-000-01, Radweste Helper - Solid Radwaste .

t Lompaction 1 09-19-84  ;

T003-006-01 Radwaste Helper - Redweste ';

4' , ,

. Solidification 1 09-TE-84 't W3T004-000-00. Radweste Helper - Radioactive Material Classification and Qualt+1 cation 1 04-sn-33  :

W3T004-001 Radwante Helfar - Radioactive '

Material Packaging -

04-16-83 WQT004-002-00. Radweste Helper - Marking. i Labeling. Slacarding Requirement f or Shipments -

d4-18-83 >

W3T005-000-00 Radweste Helper - Radioactive  !

Material Shipping Papers -

04-19-83 T017-000-00 Radweste Helper - Radioactive

  • l Shipments .

0 09-08-84 T010-000-00, Radweste Helper - Dry Waste .

l Segregati on 0 03~11-95  ;

T901-000-00, Radman Boftware 0 08-30-84 ,

QO-Ibt:dQD ICelDiD9.GbtEkliS13 T501-000-00, Basic Radweste - 0'5-02-86

-T506-000-01, Radweste Equipment Operation - 09-08-86 T502-000-00, Handling and Contrel of DAW - 05-02-86 T503-000-00, Packaging of DAW - 05-02-86

-T510-000-00, Radioactive Material /Radweste Shipping - 05-02-86 ,

T511-000-00, Contract Decon Technician Quals - 07-30-86 -

2

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4

! triter-0+ftre Correspondence. 5. Develle ALF4,L) to file.

Subject:

"!E pul l et. i n 74-19. Fechaotng of Low-Level Radioactive Weste for Transport and j hur 141 " . dated Julv-19. 1995. Sertel No. W'FSPO4SS 'j i

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