ML20097D975

Responds to NRC Re Violations & Deviations Noted in Insp Rept 50-247/84-14.Corrective Actions:Radwaste Supervisors Instructed in Requirements of Revised Certificate of Compliance

ML20097D975
Person / Time
Site:	Indian Point
Issue date:	08/31/1984
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IEB-79-19, NUDOCS 8409180061
Download: ML20097D975 (6)

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< John D. O'Toole Vice Presgient Consoidated Edison Cornpany of New York, Inc.

4 Irying Place, New York. NY 10003 Telephone (212) 460-2533 August 31, 1984 Re Indian Point Unit No. 2 Docket No. 50-247 Mr. Thomas T. Martin, Diractor Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pa. 19406 Dear Mr. Martin This refers to I.E. Inspection 50-247/84-14 conducted by Ms. R. T. Hogan of your office on June 18-22, 1984 of activities authorized by NRC License No. DPR-26 at Indian Point Unit No. 2. Your August 1, 1984 letter stated that it appeared that certain of our activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A. Our response to the items of non-compliance is presented in Attachment A to this letter.

Your letter also contains a Notice of Deviation. Our response to this Notice is presented in Attachment B to this letter.

Should you or your staff havc any questions, please contact us.

Very ruly yours,

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$u , ff cc: Senior Resident Inspector U. S. Nuclear Regttlatory Commission P. O. Box 38 Buchanan, New York 10511 k 0 4 .

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Indian Point Unit No. 2 Docket No. 50-247 ATTACHMENT A Response to Appendix A Notice of Violation 50-247/84-14 VIOLATION A 10 CFR 71.12(c) requires that a person using a package to transport licensed material must*have a copy of the Certificate of Compliance, and the person must also comply with the conditions of the certificate.

1. Certificate of Compliance No. 6601, Revision No. 15, requires that prior to each shipment, the packaging must be leak tested in accordance with Section 8.2.2 of the application.

Contrary to the above, the licensee did not perform a leak test prior to the Type B quantity shipment of resin made on May 1, 1984 in a cask having the Certificate of Compliance No. 6601.

2. Certificate of Compliance No. 6601, Revision No. 15, requires that the external dose rate at 3 feet from the surface of the package not exceed 125 mrem /hr.

Contrary to the above, the licensee did not determine if a package shipped on May 1, 1984, having the Certificate of Compliance No. 6601, had an external dose rate at 3 feet not exceeding 125 mrem /hr.

This is a Severity Level IV violation (Supplement V)

PESPONSE

1. The pressure test required by Certificate of Compliance 6601 Rev;. 15 was not conducted on May 1, 1984.

An inspection conducted at the burial sito upon receipt of the shipment dete rmined that there was no leakage into or out of the shipping cask. In addition, Chem Nuclear Systems Incorporated (CNSI) confirmed the required annual pressure test had been conducted.

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F,.' ,1 In immediate . response to this . violation, Rad Waste . supervisors were L ' instructed in the requirements of this revised Certificate of

. Compliance.

'To prevent recurrence of this. event, - ' a check-off list was incorporated in procedure EHS- 4.303 " Shipping Cask liandling Procedure" . to ensure the leak test is completed. This procedure wus implemented on August 17, 1984.

~2. _ Included as Attachment C is a copy of the . survey of shipment 84-23W

' showing a 5 mr/hr dose rate at threo feet. Additionally, a contact survey reading .on the cask showed a reading of 35 mr/hr, which would

-preclude a dose at three feet of 125 mr/hr.

VIOLATION B Technical .. Specification 6.8'.2 requires each procedure that meets or exceeds the requirements and recommendation of Sections 5.1 and 5.3 of ANSI 18.7-1972, and Appendix "A" of USA 2C Regulatory Guide 1.33 be reviewed and approved for implementation in accordance with a written administrative control procedure approved by the appropriate General Manager, and with the concurrence. of Station thtclear Safety Committee and the Nuclear Facilities Safety Committee.

Contrary to the above, the licensee has implemented a transport

! package loading procedure and the procedure wa not reviewed and approved for implementation in accordance with written administrative control procedure approved by the appropriate General Managt e, and with the concurrence of the Station Nuclear Safety Committee and the Nuclear Facilities. Safety Committee.

This is a Severity Level V violation (Supplement V) p

RESPONSE

In immediate response to the ' above violation, the cask associated with the transport package loading procedure was immediately removed

from use.

To prevent rect.rrence of this event, procedure Ells 4.303 " Shipping Cask Handling Procedure" was revised. 'It includes as addend, the above mentioned procedure and all pertinent vendor Cask IIandling' t Procedures for containers used at Indian Point, including Certificates of Compliance and ' air leak test procedures. This procedure was reviewed and approved for implementation on Augus( 17, 1984 ~ 1n accordance with Station Administrative Order 102, a written administrative control procedure approved by the appropriate General Manager, and with the concurrence of SNSC and the Nuclear Facilities Safety' Committee.

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Indian Point Unit No. 2' Docket No. 50-247 ATTACHMENT B Response to Appendix B Notice of Deviation DEVIATION IE Bulletin No. ~ 79-19 states that licensees should " provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements - and in your (the licensee's) instructions and operating procedures for all personnel involved in the transfer, packaging and transpot' of radioactive material. . ." In your response to IE Bulletin No. 79-15, dated September 24, 1979, you stated - that " training and periodic re. raining -in the DOT and NRC regulatory requirements, the wacte burial license requirements, and

! instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive materiel will be implemented by March 1, 1980. A record of training dates attendees and subject material will be maintained."

Contrary to the above, Quality Control inspectors involved in the transport of radioactive materials have not been trained in DOT and NRC 'regulatcry requirements, the waste burial license requirements and instructions and operating procedures.

RESPONSE

The .QC Manager has reviewed from an operational and QC viewpoint the

! requirements, ._ instructions and procedures discussed in the notice with the' inspectors normally involved with radwaste inspections.

Only. the inspectors who have received this retraining will be assigned to radwaste shipments until a revised training program is implemented.

We have reviewed our records and found that since 1982, 189 dnspections were performed by Quality Control (QC) using a checklist which QC helped develop based on DOT, NRC and waste burial license requirements. Two inspectors have performed 137 of the 189 inspections and thereby have the most experience in all QC aspects of Rad Waste Shipment at the site. As was explained to the NRC inspector, QC follows a checklist which verifles that certain visual checks are made of equipment, that radwaste procedures are followed, and that the information required, e.g., check sheets and calculations, are in the document package or are not required. The inspections and their scope have been designed so that the QC inspectors verify characteristics or attributes which demonstrate adherence- to procedures and regulations referenced therein without examining every company action.

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QA will review the existing QC checklist and radwaste transfer, packaging, and operating procedures to insure that adequate QC inspection poir.ts are included in existing inspection checklists. QC inspectors performing radwaste inspections will be trained to perform inspections to the revised checklist. QA is also reviewing CI-240-1 supplement 1. " Quality Assurance Program for Radioactive Material Packages, and Quality Control Requirements for Radioactive Waste Classification and Characterization (Form)" to assure it appropriately addresses the training concerns identified in the notice. QA/QC personnel involved in the inspection of the transport of radioactive material will complete fomal training in the DOT, NRC regulatory requirements, and the waste burial license requirements by December 31, 1984.

To prevent recurrence or the deviation, requirements for the formal training and retraining of personnel will be incorporated into the QA Training Progr?It. This will be accomplished by December 31, 1984.

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