ML20127B112
| ML20127B112 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/06/1985 |
| From: | Bicehouse H, Clemons P, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127B106 | List: |
| References | |
| 50-245-85-11, 50-336-85-14, NUDOCS 8506210358 | |
| Download: ML20127B112 (15) | |
See also: IR 05000245/1985011
Text
{{#Wiki_filter:- . I I U.S. NUCLEAR REGULATORY COMMISSION REGION I 50-245/85-11 Report No. 50-336/85-14 50-245 Docket No. 50-336 . OPR-21 License No. OPR-65 Priority -- Category C Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Point Nuclear Power Station, Units I and 2 Inspection At: Waterford, Connecticut and Berlin, Connecticut Inspection Conducted: April 15-19, 1985 Inspectors: M,YmMs [///h~ M. M. Sha'R iki,~ Chief PWR Jadiation ~date ~ Safety Section $Nnm& A L P. Clemons, Radiation Specialist / data $$m& h h$ Ti. Bicehouse, Rad 1#. ion Specialist ' dite Approved by: MY e,.gf M / [[/N f' M. M. Shantaky, ChiefAWR Radiation ' date Safety Section Inspection Summary: Inspection Conducted on April 15-19, 1985 (Combined Inspection Report Nos. 50-245/65-11: 50-336/85-14) Areas Inspected: Special announced inspection of the licensee's transportation program including: organization, personnel selection, qualification and training, shipments, quality assurance / quality control, procedures, procurement and selection of packages, preparation of packages for shipment, and delivery of packages to carriers. The inspection involved 102 inspector-hours onsite and at the corporate offices by two regionally-based inspectors and the Chief, PWR Radiation Safety Section. Results: An apparent violation was noted concerning failure to follow procedures for receipt inspections. Identified weaknesses noted in Appendix C are discussed in this report. 2 6"188R 838 % 0 PDR .
, .- DETAILS 1.0 Persons Contacted 1.1 Northeast Nuclear Energy Company (NNECo)
- R. J. Asafaylo, Quality Services Supervisor
- G. J. Closius, Quality Assurance Supervisor
- R. J. Herbert, Station Services Superintendent
- C. Hinze, Senior Station Technician - Quality Control
- J. P. Kangley, Radiological Services Supervisor
- J. S. Kienan, Operations Supervisor - Unit 2
- J. E. Laine, Radiation Protectior Supervisor
- E. J. Mroczka, Station Superintendent
- J. M. Wood, Radioactive Materials Handling Supervisor
1.2 Northeast Utilities Service Company (NUSCO) R. O. Bagley, Chairman, Radioactive Waste Transportation Review Group E. Brezinski, Nuclear Fuels Branch
- J. M. Burke, Engineer - Quality Assurance
- A. J. Colello, Senior Engineer - Quality Assurance
R. A. Crandall, Supervisor - Radiological Engineering Section
- H. D. Depew, Senior Radiation Protection Technician
- J. W. Doroski, Radiological Engineer
M. Hornyak, Quality Assurance Engineering Specialist W. R. Koste, Senior Engineer
- G. W. McElhone, Betterment / Construction Quality Assurance Supervisor
R. C. Rogers, Manager, Radiological Assessment Branch
- A. C. Saunders, Betterment /cosntruction Quality Assuraace Technician
H. W. Siegrist, Radiclogical Protection Section Supervisor
- M. Sforza, Engineer - Quality Assurance
Other individuals were also contacted during the inspection.
- denotes those individuals attending the exit interview on April 19,
1985. 2.0 Purpose The purpose of this special safety inspection was to review the transportation program during operation. The following areas were reviewed: Organization; - Personnel Selection, Qualification and Training; - - - _ - - _ - _ _ - - . - - - - - - - - - . - - - - _ - - - . . - - - _ . _ - . - - - .
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Shipments of Radioactive Material; - - Quality Assurance Program; , Procedures; - Procurement and Selection of Packages; - i ] Preparation of Packages for Shipment; - i - Delivery of Packages to Carriers , 3.0 Radwaste Transportation Program Organization ! .The inspector examined the program organization with regard to organiza- i tion structure, assignment of responsibilities and authorities, managegient j oversight, and inter / intra departmental communications. The inspectors .~ assessment of this area was based on interviews with licensee personnel, j examination of ongoing operations, and review of procedures and applicable i records. 4 l 3.1 Program Organizational Authorities and Responsibilities
. I I The organizational structure of the Radwaste Material Handling (RMH) ] group was clearly defined. The group was composed of five RMH Technicians i supervised by the RMH Supervisor. The RMH Supervisor reports to the i Radiological Services Supervisor who in turn reports to the Station - j Services Superintendent. The licensee stated that, to improve management oversight in this area, a reorganization of tra RMH group will be imple- , ] mented in the near future. Under the new reorganization the RMH Super- , visor will report to the Health Physics Supervisor. L ! The RMH group authorities, responsibilities and interfaces with other site j groups were clearly established by Administrative Control Procedure (ACP) 6.07 Revision 5, " Management of Radioactive Waste", Millstone Station , r ' Organizational Charts - January 1985, and ACP-QA-1.02 Revision 15,
" Organization and Responsibilities". However, the RMH group interfaces 1 with Corporate staff (i.e. Radiological Assessment Branch) were not
clearly defined. The licensee stated that improvement in this area will
be achieved by the reactivation of the Radwaste Review Committee with j members from the site and the Corporate staffs. l The inspector examined the staffing of the RMH group and interfacing . groups as it related to packaging and transportation of radioactive l , ' materials. The RMH group was supported by personnel from other site
groups (i.e. operations, chemistry and site QA/QC). The inspector dis- ! cussed with the licensee the RMH group staffing (i.e. five Radwaste
! Technicians at Millstone Units 1 and 2 compared with the ten Radwaste l Technicians at the Haddam Neck plant). The licensee stated that the , i Radwaste Technicians at Haddam Neck have additional responsibilities for area decontamination'and respiratory protection equipment decontamination. ,
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. 4 The licensee stated that it should be noted that recently increased effort by the RMH group was needed due to additional radwaste packaging and transportation operations (i.e. thermal shield shipments); however, the RMH group staffing will be re-examined. 3.2 Manacement Oversight Through examinations of procedures, records and interview of licensee's personnel, the inspector identified the following weaknesses: During absence of the RMH Supervisor, a Senior Radiation Protection -- Technician performs certain RMH Supervisor functions including sign- ing of shipments for release from the site. The Senior Radiation Protection Technician's training records indicated a lack of adequate training to enable the individual to effectively act on behalf of the RMH Supervisor (Details, Paragraph 4). By a memorandum from the Vice President, Nuclear Operations -- to distribution dated March 2, 1981, (No. 81-GN-161), a Radwaste Review Comnittee (RRC) was established. The committee members were from the Connecticut Yankee site, Millstone site and the corporate office. . The RRC was chartered with the responsibility to effectively address and resolve present and future radwaste problems for both Connecticut Yankee and Millstone sites. The inspector noted that the RRC appeared to be instrumental and effective in prescribing recommenda- tions for radwaste volume reduction at both sites. Further examination of the RRC activities and review of the commit- tee's meeting minutes indicated that the committee did not meet since May 12, 1983. The lack of committee's activity was discussed with licensee's management. The licensee committed to reactivating this committee. The committee will meet by the middle of May 1985 to discuss current problems in radwaste transportation and to re-establish new goals. The plant procedures require the Radiological Services Supervisor to -- periodically review radwaste procedures, records and logs. The inspector noted that the Radiological Services Supervisor reviewed certain radwaste packaging and transportation procedures. However, other radwaste records and logs were not reviewed. The licensee stated that the term " periodically" will be defined in the proco- dures. Also, the new reorganization will place the RMH group under the Health Physics Supervisor and will allow for a more timely review of radwaste packaging and transportation procedures, records and logs. Licensee's actions to upgrade this area will be examined during a sub- scquent inspection (50-245/85-11-10 and 50-336/85-14-10). , _ - _
-.- a J 5 3.3 Communication The inspector examined the intra and inter groups communication as it . applies to the RMH activities. Communications within the RMH group appeared to be adequate to relay necessary information between the group Technicians and the Supervisor. Good communication was also evident between the RMH group and the rest of the health physics organization. The inspector discussed with the licensee the apparent communication problems between RMH group and other site groups. Those apparent communi- cation problems had partially contributed to the lack of QA involvement in onsite receipt inspection of a " Category I" radwaste solidification system i and the operations of the system without QA involvement as required by plant procedures and the QA Topical Report (Details, Paragraph 6). The licensee stated this area will be examined. 4. personnel Selection. Qualification and Training The licensee's program for selection, training and qualification of per- sonnel assigned to collecting, processing, preparing, packaging and shipping licensed materials was reviewed against criteria and commitments provided in the following: 1 Technical Specification 6.3, " Facility Staff Qualifications"; - ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant - . Personnel"; ' Te: bnical Specification 6.4, " Training"; - ANSI N18.1-1971, Section 5.5, " Retraining and Replacement Training"; - , IE Bulletin No. 79-19, " Packaging of Low-Level Radioactive Waste for
- Transport and Burial" (August 10,1979); ' Letter W. G. Counsil (NNECo) to B. H. Grier (NRC-RI) dated September I - 19, 1979- i 10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program"; - ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program - > Audit Personnel for Nuclear Power Plants"; and 10 CFR 71.105(d), " Quality assurance program". - The major elements of the licensee's program reviewed included: the basis used for the selection of personnel to be trained; - the training schedules, lesson plans and performance of the training; - i i L d , , , - , , . . . , - - . _ - -..y,... ,-.,---.,,.,y, f. , . . . . ..n.y-, _w.,.m .,n, ,..%,...my .,,%%,n- ,_,._..m ,.e_.m. _ y_m _ ,,.~, -
. $ the determination of the individual's competence in the training - given; and the methods used to inform personnel of changes in procedures and - requirements. 4.1 Radioactive Materials Handling Section (NNECo) The licensee's performance in selecting, training and qualifying personnel assigned to the Radioactive Materials Handling Section was determined by: review of assigned duties for the Radioactive Materials Handling - l Supervisor (RMHS), Senior Radiation Protection Technician, Radwaste ' Technicians and Health Physics Technicians assigned to the section; examination of lesson plans and training records for 10 training, - ' retraining and special-training courses provided in-house or by contracted organizations presented since 1982; discussions and interviews with the RMHS and members of his staff; - and ,' review of controlled routing and document acknowledgement records - for procedural training. Within the scope of this review, the following weakness was noted: The Senior Radiation Protection Technician assumes the duties of the RMHS in the latter's absence. Since his assignment in 1984, the Senior Radia- tion Protection Technician had received only limited training in packaging and shipping requirements. The Senior Radiation Protection Technician had received training in procedures and attended 2 days of a 5-day contrac- tor-given training course. In contrast, records indicated that the RMHS had attended at least 9 training, retraining and specialized training courses in packaging and shipping requirements since 1982. Since the Senior Radiation Protection Technician acted as the RMHS in the latter's absence, failure to ensure that he had adequate training in packaging and shipping requirements constituted a weakness in the licensee's training and qualification program. At the exit interview on April 19, 1985, the licensee's representative stated that the training of the Senior Radiation Protection Technician would be examined and additional training provided
as appropitate. The training of the Senior Radiation Protection Techni- clan will be examined in a subsequent inspection (50-245/85-11-01 and 50-336/85-14-01). i ! _ _ _ _ . . - _ _ _ - -. -
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< , i 7 4.2 Quality Assurance / Control Section (NNECo) The licensee's performance in selecting, training and qualifying Quality Assurance (QA) Monitors and Quality Control (QC) Inspectors providing overview of radioactive materials shipments was determined by: review of duties assigned to QA Monitors and QC Inspectors; - examination of NUSCO Quality Assurance training program plans and - records; examination of training records for shipping-related training - programs for QC Inspectors; and discussions and interviews of the Quality Assurance Supervisor and - selected members of his staff. Within the scope of this review, no violations deviations or weaknesses were noted. The site Quality Assurance / Quality Control personnel appeared to be adequately trained to perform their duties. 4.3 Quality Assurance (NUSCO) On April 8, 1985, a corpcrate quality assurance audit of the transporta- tion activities at the Millstone Point Nuclear Power Station was performed by a quality assurance auditor. The training and qualification in radio- active materials shipping for the auditor was reviewed and the following weakness was noted: Although qualified as an auditor under ANSI /ASME N45.2.23-1978, the auditor had not received any training in shipping and packaging require- ments. Failure to assign an auditor with training in shipping and packaging requirements to audit transportation activities constitutes a weakness in the licensee's quality assurance program. At the exit interview on April 19, 1985, the licensee stated that appropriate technical expertise would be included in any future audit of transportation activities. The training of corporate QA audit team reviewing transportation activities will be reviewed in a subsequent inspection (50-245/85-11-02 and 50-336/85-14-02). 5. Shipments of Radioactive Material The licensee's program for the transportation of radioactive material was reviewed against the criteria in 10 CFR 71.12. " General License: NRC approved package". The licensee's performance relative to these criteria was determined by discussions with the Radioactive Materials Handling Supervisor, and by reviewing shipping documents.
. . -- - . . _ _ _ - _ - . . . - - . - _ . . - _ . . - . i . , l 8 ! ' 1 , . l Within the scope of this review, the following was identified:
' The licensee has made several shipments of radioactive material during the i period August 1984 - March 1985 to other Itcensees, and to the burial site in Barnwell, South Carolina. The inspector examined previous shipments that were made in NRC approved packages. The inspector's review revealed > i a lack of attention to technical detail as indicated by the following: On or about October 15, 1984, the licensee made a shipment of -- } radioactive waste to the burial site in Barnwell, South Carolina. Due to inadequate interpretation of radiation survey data taken ' , ! underwater, the licensee improperly listed the container dose rate
2 as 500 R/hr. The actual container do n rate measured by the State l q of South Carolina was 30,000 R/hr. i ! On or about July 26-27, 1984, the licensee made a shipment of radio- -- ' ! active waste to the burial site in Barnwell, South Carolina. On 1 August 3,1984, a representative of the State of South Carolina 1 surveyed the liner containing the material, and the contact dose rate l observed was 10,000 mr/hr. The licensee had indicated a contact dose c t j rate of 150 mr/hr on the documents accompanying the shipment. S i j On or about January 7,1985 the licensee made a shipment of irradt- -- ! ated control rod handle assemblies to another licensee in California. j The shipment contained 7,360 Curies of mixed fission products. 10 , - CFR 30.41, " Transfer of byproduct material" permits licensees to transfer byproduct material if the licensee has determined (before 3 ' transferring material to a specific licensee) that the recipient's ! Itcense authorizes the receipt of the type, fonn and quantity of by- ! I product material being transferred. During this inspection, the i inspector reviewed the shipping documents for the shipment made on ! } January 7, 1985. The licensee identified the recipient's license i permitting the receipt of 7,360 curies of mixed fission products as ! ' Special Nuclear Material License No. SNM-960. This Ifeense does not authorize the receipt of 7,360 Curtes of mixed fission products. ! , ! Further investigation revealed that the licensee did have a copy of ' ' the recipient's appropriate license. i 1 j On March 4, 1985, the licensee shipped 207 Curies of radioactive -- material contained in dewatered resin to the burial site in Barnwell,
> i South Carolina. The shipment was made in package Model No. CNS ' j 8-120, certificate of Compliance (CoC) No. 6601. !
The Itcensee has developed a " Millstone Inspection Plan" to be used , by personnel to assure compliance with the conditions of the CoC. 4 l The inspector determined that the "M111 stone Inspection Plan", as it j presently exists, does not address the following conditions of CoC i No. 6601: i e !
I f i ' i
. . 9 a. Prior to each shipment, a determination must be made that closure seal replacement is current with the seal replacement schedule in Section 8.2.4 of the application. b. The packaging must be leak tested once every 12 months in accordance with Section 8.1.3 of the application. The licensee's records for any given shipment during the period of -- July 1984 - March 1985, did not " stand alone". Certain records of a shipment were found with the Radioactive Materials Handling Super- visor, with the QA/QC organization, in the Records Storage Area and in the corporate office in Berlin, Connecticut. The licensee stated that appropriate improvements to consolidate transportation records will be made. Within the scope of this review, no violations were identified. The maintenance of " stand alone" records will be reviewed during a subsequent inspection. (50-245/85-11-03; 50-336/85-14-03). 6.0 Quality Assurance QA/ Quality Control QC A Quality Assurance program is required to be established in accordance with the provisions of 10 CFR 71, Subpart H. A Commission-approved QA program which satisfies the applicable criteria of Appendix B of 10 CFR 50 and which is established, maintained and executed with regard to trans- port packages is acceptable to meet the requirements of 10 CFR 71 Subpart H. The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to transport packages. In addition to the general QC provisions required by 10 CFR 50, Appendix B, specific QC requirements to assure compliance with 10 CFR 61.55 and 41.56 were required by 10 CFR 20.311. Theinspectorexaminedthepackagi.19andtransportationQA/QC activities being implemented by the licensee s site and corporate QA organizations. 6.1 Site QA/QC The site QA organization was responsible for implementing all applicable QA criteria to packaging and transportat un of radwaste. The corporate QA organization was responsible for performing QA audits. The site QA organization was operating in accordance with established Administrative Control Procedures. The site QA organization provided QA verification of packaging compliance upcn arrival at the site. A checklist with applicable items was used to verify compliance with the packaging (i.e. Casks) Certificate of Compliance (CoC). Prior to shipment departure from the site, a QA list was used by the site QA Technicians to check compliance with applicable requirements. These checklists were developed to implement the requirements of packaging and transportation procedures. - - - . . . . - - . -
__________________ , l 10 The inspector examined the site QA organization involvement in the receipt of a radwaste solidification system. The system was provided by Pacific Nuclear Systems, Inc. and the Purchase Order (No. 811624) indicated that the system was a Category I QA item. The Pacific Nuclear Systems, Inc. solidification system was used at least three times during 1984 for the purpose of solidifying thermal shield > t chips to be disposed of at the burial site in Barnwell, South Carolina. On, or about August 27, 1984, November 2, 1984 and December 18, 1984 three radioactive waste shipments of thermal shield chips (containing 1215 Curies, 946 Curies and 2311 Curies respectively) were processed by the system and sent to Barnwell, South Carolina. , Plant QA involvement in the receipt, installation, storage, and handling of the system was not evident. Based on the inspector review of the QA l records and discussions with personnel, the inspector concluded that the Pacific Nuclear Systems, Inc. solidification system (a Category I system) was not receipt inspected and released by the site QA organization. This was contrav to the requiretrents of QA procedures including Procedure No. ACP-QA-4.04 Revision 8. The inspector stated that failure to implement QA procedures was in apparent violation of Section 6.8 of the plant Technical Specifications (245/85-11-04 and 336/85-14-04). The inspector examined the licensee's Quality Control (QC) program to assure proper classification and characterization of wastes in accordance with the requirements of 10 CFR 61.55 and 61.56. The inspector noted that the licensee had implemented Procedures No. RW6001/26001 and RW6002/26002 l; for 10 CFR Part 61 Compliance. However, a comprehensive QC program was not established to implement the regt frements of 10 CFR 20.311. The site QA organization had a limited involvenent in assuring that the dewatering operation was performed. The site QA Technicians were to verify that a given volume of water was removed from the package. However, the proce- dures failed to address QA monitoring during the dewatering process and solidification operation. The inspector discussed with the licensee the QC requirements of 10 CFR 20.311. This regulation requires the licensee to conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56. The licenses stated that the current QC pro 0 ram will be upgraded and QA monitoring of transportation activities will be performed at a more frequent basis. Upgrades to the current QC program and QA monitoring activities will be examined during subsequent inspections (50-245/85-11 -05 and 50-336/85-14-05), 6.2 Cerporate_QA The inspector examined the Corporate QA program and its applicability to packaging and transportation of radioactive waste material. Corporate QA audits of this area were being performed by the Corporate QA staff. The inspector examined a recent Corporate Audit ( A 60425, April 1985) covering .. .- - .
. , 11 certain aspects of the Technical Specifications and the Radioactive Trans- portation Packaging Program. Through discussions with the corporate QA staff, examination of the QA Topical Report, review of QA procedures and QA audits, the inspector identified the following weaknesses: Program Implementing Procedures -- Although the QA Topical Report, Appendix A, indicated that items and services associated with radioactive waste packaging and transporta- tion are considered Category I QA items, the Corporate NEO and ACP procedures did not clearly reflect the QA Topical Report require- ments. This caused an apparent confusion as to the applicability of 10 CFR 50, Appendix B, criteria to certain packaging and transporta- tion activities. Also, the acceptance criteria for a given packaging or transportation activity were not clearly defined. The licensee stated that the QA implementing procedures will be revised to correct these weaknesses by August 1985. These corrections will be reviewed during a subsequent inspection (50-245/85-11-06 and 50-336/85-14- 06). Audit Team Technical Expertise -- The inspector examined the qualifications and training of the Corpor- ate OA Auditors. The auditors were qualified as QA Auditors per ANSI N45.2.23. However, lack of training in the radwaste packaging and transportation area was evident. The April 1985 audit was performed by a QA Auditor without any technical expertise in radwaste packaging and transportation. The licensee stated that all future QA audits will be performed by a team e tch includes the needed technical expertise in this area. QA dadit team qualifications will be reviewed during a subsequent inspection (50-245/85-11-07 and 50-336/- 85-14-07). Monitoring Activities -- The inspector noted that QA monitoring procedures were applied to the cadwaste transportation area in a limited scope and infrequent fashion. The last QA monitoring activity at Millstone was in 1983. The licenseo stated that monitoring activities will be performed in the future on a more frequent basis. QA monitoring of radwaste transportation activities will be reviewed in a subsequent inspection (50-245/85-11-08 and 50-336/85-14-08). 6.3 Radioactive Waste Transpor_tation Review Group r _ As a result of repeated problems in the radwaste packaging and transporta- tion area, and the subsequent Enforcement Conference held in Region I on March 25, 1985, the licenseo committed to perform a comprehensive audit in this area. To perform this internal audit the licensee formed the Radio-
. , 12 active Waste Transportation Review Group (RWTRG) and developed an action plan. The inspector reviewed the RWTRG action plan and noted that the final report on the status of the program was scheduled for June 1, 1985. 7. Procedures The licensee's procedures for the preparation, classification, packaging and shipping of radwastes were reviewed against criteria provided in: Technical Specification 6.8, " Procedures"; - NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements - (Operation)"; 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures and - Drawings"; 10 CFR 71.5, " Transportation of Licensed Materials"; - 10 CFR 71.12, " General License: NRC Approved Packages"; - 10 CFR 20.311. " Transfer for Disposal and Manifests"; and - NRC-NMSS Low-Level Waste Licensing Branch, " Final Waste - Classification and Waste Form Technical Position Papers" (May 1983). Selected procedures and radwa de shipment records were reviewed and discussed with the Radioactive Materials Handling Supervisor and members of his staff. 7.1 Administrative Control Procedures The following Administrative Control Procedures (ACP) were reviewed and their implementation in selected radwaste handling and shipping operations was examined: ACP-QA-4.04, " Instructions for Packaging, Shipping, Receiving, - Storage ar.d Handling", Revision 8(5/17/84); ACP-QA-5.01, "Non-Conforming Material and Parts", Revision 14 - (2/21/85); ACP-QA-6.04, " Radioactive Material Shipping Requirements", Revision - 15(4/18/85); ACP-6.07, " Management of Radioactive Waste", Revision 5 (1/3/85) - Within the scope of this review, no violations were identified. - ----------- ------------------------ -- ------ - - --- -
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - ___ _ _ _ _ . . ' 13 . 7.2 Radwaste Operating Procedures , The following Radioactive Waste (RW) operating procedures were reviewed and their implementation in selected handling and shipping operations was
examined: RW 6001/26001/36001, " Waste Classification Implementation Program", - Revision 0(11/27/84); RW 6002/26002/36002, " Determination of the Waste Classification for - Radioactive Waste Offered for Shallow Land Burial", Revision 0 (11/27/84); RW 6003/26003/36003, " Radioactive Materials Shipping Compliance", - Revision 0 (1/3/85); 7 RW 6004/26004/36004, " Shipment of Radwastes", Revision 0 (1/3/85); - - RW 6005/26005/36005, " General Radioactive Materials Shipment", - Revision 0 (1/3/85); J RW 6006/26006/36006, " Receipt of Radioactive Material", Revision 0 < - (1/3/85); RW 6007/26007/36007, " Container Control and Accountability", - Revision 0 (1/3/85); RW 6008/26008/36008, " Drum Compacting Procedure", Revision 0 -
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(1/22/85); RW 6009/26009/36009, "Radwaste Shipment Survey Proceduro", Revision - 0(2/27/85); RW 6010/26010/36010. " Loading of Chem-Nuc Shipment Cask", Revision 0 - (2/27/85); RW 6011/26011/36011. " Operating the Mobilo Shield Assembly (ATCOR - Cask)", Revision 0(2/27/85) Since the RW Procedures covered operations from approximately November
1984 untti the time of this inspection, previously used procedures in the , Health Physics (HP) Procedure series were also reviewed as applicable to various shipments. , Within the scope of this review, the following items were noted; From December 1983 untti November 1984, the licensee did not have - procedures to implement wasto classification under 10 CFR 20.311/10 CFR 61.55. Each of the following procedures contained the statomont: "Each (package typo) must be classified por 10 CFR 61.55..." but did not provide impicmenting instructions and acceptance critoriat -
\\ - . 14 . . HP 928/2928, " Shipment of Radioactive Material";
HP 928/2928 A-2, " Shipment of Solidified Liquid Radioactive
Waste and Spent Resin (Cask)"; HP 928/2928 A-3, " Shipment of Radioactivity Contaminated Com-
pactible Waste"; and HP 928/2928 A-4, " Shipment of Radioactive Material In Drums In
Casks". This apparent violation of 10 CFR 20.311(d)(1) was identified and corrected by the licensee by the adoption of RW 6001/2600/36001 and RW 6002/26002/36002 in November 1984. Several procedures, (e.g. RW 6003/26003/36003, RW 6004/26004/36004, - and RW 6005/26005/36005), frequently used reference to sections of 49 CFR in lieu of step-by-step instructions and acceptance criteria. ANSI N18.7-1976/ANS-3.2," Administrative Controls and Quality Assur- ance for the Operational Phase of Nuclear Power Plants", Section 5.3.2(7) recommends that a procedure contain step-by-step instruc- tions in the degree of detail necessary for performing a required function or task. Section 5.3.2(8) recommends acceptance criteria in procedures against which the success or failure of an activity can be judged. Since Radwaste Technicians and others using the procedures do not generally know the transportation requirements in 49 CFR and have difficulty in interpreting and applying them to specific ship- ments failure to provide step-by-step instructions and acceptance criteria 1' the aforementioned procedures constitutes a weakness in the administrative controls of packaging and shipping activities. At the exit interview on April 19, 1985, the Itconsee stated that procedures would be reviewed, revised as necessary to include step-by-step instructions and acceptance critoria, and reviewed and approved by August 1, 1985. Radioactive waste procedures will be reviewed for step-by-step instructions and acceptance criteria during a subsequent inspection (50-245/85-11-09 and 50-336/85-14-09). 7.3 Special Procedures Shipment No. 85-004-1, (General Electric Model IF-300 cask containing control rod blades), was reviewed to determine implementation of Special Procedure (SP) 85-1-1, " Handling IF-300 shipping Cask," Revision 0, 2/1/85. Shipment No. 85-004-1 left the site on or about March 20, 1985 and was buried at the U.S. Ecology site in Washington on April 4, 1985. The preparation, labeling, quality control, classification and related supporting documentation were reviewed. The special procedure was adequately implemented for this shipment. - -
_____ . 1 15 8. procurement and Selection of Packages The licensee's program for the selection of packages was reviewed against the requirements of 10 CFR 71.12 " General license; NRC approved package", and the DOT requirements of 49 CFR Part 173, " Shippers General , Requirements for Shipments and Packagings." , The licensee's performance relative to these criteria was determined by , interviewing the Radioactive Materials Handling Supervisor, and reviewing documents. The licensee has utilized several NRC approved packages for the shipment of radioactive materials during the period July 1984 - March 1985. Following are some examples of the packages used: , l Model No. CNS-8-120 (CoC 6601) ' Model No. CNS-14-195H (CoC 9094) !
Model No. GE-1600 (CoC 9044) l Model No. 0H-142 (CoC 9073) In addition, the licensee made numerous shipments of radioactive waste using 55 gallon drums and 4'x 4'x 8' metal boxes. Within the scope of this review, no violations were identified. f 9. Preparation of Packages for Shipment The licensee's program for the preparation of packages for shipment were reviewed against the requirements of 49 CFR Parts 172 and 173, " Shippers 4 - General Requirements for Shipments and Packagings", 10 CFR 71.87, " Routine determinations", Procedure No. RW 6004/26004/36004, " Shipment of Radwastos", and Proceduro No RW 6005/26005/36005, " General Radioactive 3
Materials Shipment." The Itconsee's performance relat've to those critoria was determined by , j discussiens with the Radioactive Materials Handling Supervisor, and by reviewing appropriato documents.
Within the scope of this review, no violations woro identified. However, " the following item was discussed with the licensoo: L The Itcenseo was not utilizing compaction for Low Specific Activity l -- (LSA) boxes. Compaction was used only for LSA drum shipments. This apparent inconsistency was discussed with the Itconsee. The Itcensee stated that the appropriate use of compaction for volume reduction ' would be considered for LSA boxos. l 10. Delivery of Packages _to Carrierj The Itcenseo's proceduros for delivering packages to carriors were reviewed against criteria provided in: I - - - -
. . 16 10 CFR 71.5(a)(1)(iii), " Placarding"; - 10 CFR 71.5(a)(1)(vi), " Shipping Papers"; - 10 CFR 20.311(b), " Shipping Manifest"; - 10 CFR 20.311(a), " Certification"; and - 10 CFR 71.5(a)(2)(iv), "Public Highway - 49 CFR Part 177." - The licensee's performance relative to these criteria was determined by review of procedures and shipping records, discussions with cognizant personnel and direct observation. Within the scope of this review, no violations or weaknesses were noted. 11. Exit Interview The inspector met with the Itcensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on April 19, 1985. The inspector summarized the purpose and scope of the inspection and findings as described in this report. At no time during this inspection was written material provided to the licensee by the tiispector. No information exempt from disclosure under 10 CFR 2.790 is discussed in this report. i e k . . . . . . }}