ML20127L762
| ML20127L762 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 06/13/1985 |
| From: | Bicehouse H, Clemons P, Myers L, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127L752 | List: |
| References | |
| 50-213-85-09, 50-213-85-9, NUDOCS 8506280122 | |
| Download: ML20127L762 (14) | |
See also: IR 05000213/1985009
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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Report No.
50-213/85-09
Docket No.
50-213
License No.
Priority --
Category C
Licensee:
Connecticut Yankee Atomic Power Company
Hartford, Connecticut 06101
Facility Name:
Haddam Neck Power Plant
Inspection At: Haddam Neck, Connecticut
Inspection Conducted: April 8-12, 1985
Inspectors: [H. Bicehouse, Radiatfon' Specialist
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P.~Clemons, Radiation Specialist
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L. Myers, Radiation Specialist
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Approved by:
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M. Shanbaky, Chief
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PWR Radiation Safety Section
Emergency Preparedness & Radiological Protection Branch
Inspection Summary:
Inspection April 8-12, 1984 (Report No. 50-213/85-09)
Areas Inspected:
Special, announced safety inspection by four region-based
inspectors of transportation activities, including: organization, personnel
selection, qualification and training, shipments of radioactive material,
quality assurance program, procedures, procurement and selection of packages,
and preparation of packages for shipment. This inspection involved 144
inspector hours on site by four regionally based inspectors.
Results: One violation was identified (a procedure was not followed, and
another procedure was not reviewed and approved as required, details in
Paragraph 7.1).
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DETAILS
1.0 Personnel Contacted
1.1 Licensee Personnel
R. Graves, Station Superintendent, Connecticut Yankee
J. DeLawrence, Acting Engineering Supervisor, Connecticut Yankee
J. Beauchamp, Quality Assurance Supervisor, Connecticut Yankee
W. Nevelos, Radiation Protection Supervisor, Connecticut Yankee
R. Haight, Radioactive Materials Handling Supervisor, Connecticut Yankee
W. Heinig, Engineering Quality Assurance Specialist, Connecticut Yankee
F. Libby, Supervisor, Design and Operations Quality Assurance
M. Hornyak, Engineering Quality Assurance Specialist, NUSCo
J. Gionet, Quality Assurance Auditor, NUSCo
1.2 NRC Personnel
M. Shanbaky, Chief, PWR Radiation Safety Section
P. Swetland, Senior Resident Inspector
H. Bicehouse, Radiation Specialist
L. Myers, Radiation Specialist
Other licensee personnel were contacted and interviewed during this
inspection.
2.0 Purspose
The purpose of this special safety inspection was to review the
licensee's transportation program with respect to the following areas:
-Organization;
-Personnel selection, qualification and training;
-Shipments of radioactive material;
-Quality assurance programs;
-Procedures;
-Procurement and selection of packages;
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-Preparation of packages for shipment; and
-Delivery of packages to carriers.
3.0 Radwaste Transportation Program Organization
The inspector examined the program organization with regard to organiza-
tion structure, assignment of responsibilities and authorities, management
oversight, and inter / intra-departmental communications.
The inspector's
assessment of this area was based on interviews with licensee personnel,
examination of ongoing operations, and review of procedures and applicable
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records.
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3.1 Program Organizational Authorities and Responsibilitier
The organizational' structure of the Radwaste Materials Handling
(RMH) group was clearly defined. The group was made up of ten Radwaste
Materials Handling Technicians supervised by the RMH Supervisor.
The
RMH Supervisor reports to the Radiation Protection Supervisor who in turn
reports to the Health Physics Supervisor. The organization charts
indicated that the RMH group had adequate supervision, and a clearly
defined reporting chain to station management.
The RMH group has the responsibilities for radioactive materials packag-
ing and transportation with the additional duties of area and respiratory
protection equipment decontamination. The RMH group authorities,
responsibilities and interfaces with other site groups were clearly
detailed in procedures ADM 11-41 Revision 7, dated March 11, 1985,
" Connecticut Yankee Administrative Control Procedure", and RAP 6.3-5,
Revision 22, dated April 8, 1985, " Radioactive Material Management."
The inspector examined the RMH group and interfacing groups staffing as it
relates to packaging and transportation of radioactive materials. The
RMH group was supported by personnel from other site groups "i.e. Opera-
tions, Chemistry and Health Physics".
The RMH group staffing, training
and qualifications (Details, Paragraph 4) were adequate to perform the
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assigned radwaste handling and transportation activities.
3.2 Management Oversight
Through examination of procedures, records and interview of licensee's
personnel, the inspector determined that the WH activities were adequate-
ly supervised. During the absence of the RMH group supervisor, the
Radiation Protection Supervisor (qualified in Radioactive Waste packaging
and transportation), provides supervision and guidance to the RMH group.
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Transportation related documents final review and approvals are performed
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only by the RMH Supervisor, Radiation Protection Supervisor or Health
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Physics Supervisor.
Individuals in these positions were found to have
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adequate training and experience in radioactive material packaging and
transportation (Details, Paragraph 4).
By a memorandum from the Vice President, Nuclear Operations, to distribu-
tion dated March 2, 1981, (No. 81-GN-161), a Radwaste Review Committee
(RRC) was established.
The committee members were from the Connecticut
Yankee site, Millstone site and the Corporate Office.
The RRC was chartered with the responsibilities of effactively addressing
and resolving 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 recommendations for radwaste
volume reduction at both sites.
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Further examination of the RRC activities and review of the committee'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.
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. Also good communication was 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. This apparent
communication problem has partially contributed to lack of QA involvement
in onsite receipt inspection of a " Category I" radwaste solidification
system 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.
4.0 Selection, Training and Qualification
The licensee's program for selection, training and qualification of
personnel assigned to shipping radioactive materials was reviewed against
criteria and commitments provided in the following:
Technical Specification 6.3, "Fardlity Staff Qualifications";
ANSI N18.1-1971, " Selection and Training Of Nuclear Power Plant
Personnel";
Technical 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 (Connecticut Yankee) to B. H. Grier (NRC-RI)
dated September 17, 1979;
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
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10 CFR 71.105(d), " Quality Assurance Program".
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The major elements of the licensee's program were reviewed including:
the basis used for the selection of personnel to be trained;
the schedules, lesson plans and performance of the training;
the determination of the individual's competence in the training
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given; and
the methods used to inform personnel of changes in procedures and
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requirements.
4.1 Radioactive Materials Handling Section Training
The licensee's performance in the selection, training and qualification
of personnel assigned to the Radioactive Materials Handling Section was
determined by:
review of the job descriptions and duties of the Radiation
Protection Supervisor (RPS), Radioactive Materials Handling
Supervisor (RMHS) and the Radioactive Waste (Radwaste) Technicians;
examination of lesson plans and training records for seven training
programs for in-house and contractor given training courses presented
since 1980;
discussions and interviews with the RPS, RMHS and selected radwaste
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technicians.
Within the scope of this review, no violations or weaknesses were noted.
The licensee had implemented monthly group meetings, on-the-job training
and annual retraining programs for Radwaste Technicians.
Radwaste
Technicians appeared to be thoroughly familiar with their duties and
responsibilities.
The licensee had initiated and maintained an adequate program to ensure
that Radwaste Technicians were fully informed of changes in procedures and
requirements.
Guidance was provided for Radwaste Technicians serving in
supervisory positions. The licensee appeared to be implementing an
effective selection, training and qualification program for personnel
assigned to the Radioactive Materials Handling Section.
4.2 Quality Assurance Section Training
The licensee's performance in the selection, training and qualification
of personnel assigned to the Quality Assurance Section as inspectors or
monitors of radioactive materials shipments was determined by:
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review of job descriptions and duties for Quality Control Inspectors
and Quality Assurance Monitors;
examination of lesson plans and training records for
shipping-related training programs; and
discussions and interviews with the Quality Assurance Supervisor and
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selected members of his staff.
Within the scope of this review, the following weakness was noted
Quality Control Inspectors did not appear to be adequately trained in
shipping and radwaste disposal requirements.
Two Quality Control
Inspectors, providing inspections of radwaste shipments, were unable to
describe acceptance criteria for:
allowable radiation levels on radwaste shipments;
" free-standing" liquids in compacted, low specific activity, radwaste
shipments;
" strong-tight" containers in radwaste drum shipments; and
waste classifications under 10 CFR 61.
The training course, "QADI-5: Radwaste Shipment", was prepared and
presented by an individual with limited documented training, in NRC and
DOT requirements.
The course was provided to the Quality Contrcl
Inspectors in December 1984. The instructor was a Quality Assurance
Engineer whose documented training consisted of one contractor provided
two-day seminar on radwaste.
Some of his students in QADI-5 had attended
the same two-day seminar.
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Since the site Quality Control Inspectors provide an independent review of
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the adherence to shipping and radwaste requirements, failure to adequately
train QC inspectors is considered a weakness in the licensee's program.
This item will be examined during a future inspection (85-09-01).
5.0 Shipments of Radioactive Material
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The licensee's program for the transportation of radioactive material was
r? viewed against the criteria in 10 CFR 71.12, " General License:
NRC
approved package".
The licensee's performance relative to these criteria
was determined by interviewing the Radiation Protection Supervisor and the
Radioactive Materials Handling Supervisor, and by reviewing shipping
documents.
Within the scope of this review, the following was identified.
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During the period of June-December 1984, the licensee made several radio-
active waste shipments to the burial site in Barnwell, SC. The shipments
investigated were made in NRC approved packages, and they all contained
dewatered resin.
On June 26, 1984, the licensee shipped about five Curies of radioactive
material contained in dewatered resin in package Model No. CNSI 14-170,
Certificate of Compliance (CoC) No. 9079, according to the licensee's
shipping documents, to Barnwell, SC.
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The inspector was given a copy of CoC No. 9079, and noted that Condition
No. 5(a)(1) of CoC No. 9079 did not identify package Model No. CNSI 14-170
as an approved package.
The approved packages identified in CoC No. 9079
were the NUPAC 14D-2.0, HN-100 Series 2 and HN-100 Series 2A.
According
to the Radioactive Materials Handling Supervisor, the package used to make
the shipment on June 26, 1984 was marked as CNSI 14-170 and HN-100 Series
2A. Apparently the package owner (Chem-Nuclear Systems, Inc.) has not
made application to the Transportation Certification Branch of the
Division of Fuel Cycle and Material Safety to incorporate package Model
No. CNSI 14-170 into Condition No. 5(a)(1)of CoC9079.
The licensee's failure to identify package Model No. CNSI 14-170 as an
unapproved package is an indication of lack of attention to detail. The
inspector stated that it is the licensee's responsibility to assure that
all conditions of the CoC are complied with and the CoC is applicable to
the package that is used.
This item will be reviewed in a subsequent inspection (85-09-02).
During Inspection 50-213/84-11 it was determined that the licensee did not
have a quality control program to assure compliance with 10 CFR 61.55 and
10 CFR 61.56. During this current inspection it was determined that the
licensee has taken steps to establish a quality control program to assure
compliance, however, several program improvements are still needed. As
indicated in Procedure No. RAP 6.3-5, " Radioactive Material Management",
dated April 8, 1985 and Procedure No. 6.3-9, "Use of USNRC Certified
Radioactive Material Packages", there is very little involvement in either
procedure by Quality Control personnel. There are no " hold points" in
either procedure to assure quality control involvement.
On Page 27 of 65 of Procedure No. RAP 6.3-5, there are many important
steps to be performed that should be verified, but the only requirement
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for QA is to verify the amount of water collected prior to sealing the
High Integrity Container.
The lack of a significant Quality Control
involvement in these operations represents a weakness in the licensee's
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program.
This item will be reviewed in a subsequent inspection (85-09-03)
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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
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and which is established, maintained and executed with regard to transport
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 packaging and transportation of radioactive
waste.
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 61.56
were mandated by 10 CFR 20.311.
The inspector examined the packaging and transportation QA/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 transportation 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 Series 1.1 and 1.2.
The site QA
organization provided QA verification of packaging compliance upon arrival
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at the site. A check list 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 check lists were developed to implement the requirements of Radia-
tion Protection Procedures NO. RAP 6.3-5, Revision 22, " Radioactive
Material Management", and 6.3-9 "Use of USNRC Certified Radioactive
Material Packages".
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The inspector examined the site QA organization involvement in the receipt
of a radwaste mobile solidification system. The system was provided by
NUS and the purchase order (No. 811646) indicated that the system is a
Category I QA item.
The mobile solidification system interface with plant
systems and potential for unmonitored releases from the system were
adequately reviewed by the plant Engineering Section. The inspector
examined the documentation of the Plant Design Change Request (PDER-603)
and the associated 10 CFR 50.59 and environmental evaluations. These
avaluations appeared adequate and complete.
Although adequate safety and environmental evaluations were performed by
the Engineering Section for the NUS System installation, Plant QA involve-
ment was not evident.
Based on the inspector review of the QA records and
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discussions with personnel, the inspector concluded that the NUS mobile
solidification system (a Category I system) was not receipt inspected and
released by the site QA organization. This was contrary to the require-
ments of QA procedures including procedures No. QA 1.2-7.1.
The inspector
stated that failure to implement QA procedures was an apparent violation
of Section 6.8 of the plant Technical Specifications. (85-09-04).
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 has implemented procedure No. SUR 5.6-14 " Sampling Guidelines
For 10 CFR Part 61 Compliance". The Health Physics and Chemistry Depart-
ments were responsible for implementing the procedures.
Limited QC
measures were established with regard to 61.55 or 61.56 by Procedure SUR
5.6-14 or Procedure No. RAP 6.3-5.
The site QA organization had a
limited involvement in assuring that dewatering operations were performed.
The site QA Technicians were to verify that a given volume of water was
removed from the package, however, no procedures monitoring was performed
by the QA organization. Also, no QA procedures for monitoring of solidi-
fication operations were available.
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
inspector stated that improvements in site QA/QC program, including
upgraded monitoring activities and QC program for 10 CFR 61 requirements,
will be examined during a future inspection (85-09-03).
6.2 Corporate QA
The Corporate QA organization is responsible for QA program
implementation at Haddam Neck and Millstone sites. The inspector examined
the Corporate QA program and its applicability to packaging and transpor-
tation of radioactive waste material.
Corporate QA audits of this area
were being performed by Corporate QA staff. The inspector examined a
recent Corporate audit (A60425, April 1985) covering certain aspects of
Technical Specifications and Radioactive Transportation Packaging Programs
at Millstone site. Through discussions with the Corporate QA staff,
examination of QA Topical Report, review of QA procedures and QA audits,
the inspector identified the following program weaknesses:
Program Implementing Procedures
Although the QA Topical Report, Appendix A indicated that items and
services associated with radioactive waste packaging and transport-
ation 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 transportation
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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 program weaknesses by August 1985.
This item will be reviewed during a subsequent inspection (85-09-05).
Audit Team Technical Expertise
The inspector examined the qualifications and training of the
Corporate QA Auditors. The auditors were qualified as QA Auditors
per ANSI N45.2.23, however, lack of training in the radwaste packag-
ing 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 audit team did not include staff
with technical expertise in the area of packaging and transportation.
The licensee stated that all future QA audits will be performed by a
team which includes the needed technical expertise in this area.
Monitoring Activities
The inspector noted that QA monitoring procydures were applied to
the radwaste transportation area in a limited scope and infrequent
fashion.
The licensee stated that monitoring activities will be
performed in the future on a more frequent basis.
Program impreve-
ments in this area will be examined during a future inspection
(85-09-06).
6.3 Radioactive Waste Transportation Review Group
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As a result of repeated problems in the radwaste transportation
area at the Millstone site and the subsequent Enforcement Confer-
ence held in Region I on March 25, 1985, the licensee committed to
perform a comprehensive audit in this area.
To perform this
internal audit, the licensee formed the Radioactive Waste Transpor-
tation 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.
The inspector stated that resolution of the RWTRG findings and
concerns will be examined during a future inspection (85-09-07).
7.0 Procedures
The licensee's procedures for preparation, classification, packaging and
shipping radwastes were reviewed against criteria provided in:
- Technical Specification 6.8, " Procedures";
- ANSI N18.7-1976, " Administrative Controls And Quality Assurance For The
Operational Phase Of Nuclear Power Plants";
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- 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
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- NRC/NMSS Low-Level Waste Licensing Branch, " Final Waste Classification
And Waste Form Technical Position Papers", (May 1983).
Selected procedures and radwaste shipment records were reviewed and
discussed with cognizant members of the licenseds staff.
The following
procedures were reviewed for conformance to the criteria:
' Administrative Control Procedure (ACP) No. 1.2-13.5, " Entry And Exit
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From Station Of Transporter For Nuclear By-Products (Radwaste),"
Revision 8 (1/25/85);
- Radiation Protection Procedure (RAP) No. 6.3-5, " Radioactive Material
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Management", Revision 22 (4/8/85);
Revision 0 (4/8/85); and
- Surveillance Procedure (SUR) No. 5.6-14, " Sampling Guidelines For 10 CFR
Part 61 Compliance", Revision 1 (3/1/85).
Within the scope of this review, the following weakness was noted:
As a result of revisions to RAP No. 6.3-5 approved April 8, 1985, ACP No.
1.2-13.5 referenced inappropriate sections of RAP 6.3-5 for acceptance
criteria for shipping containers.
This item is considered a weakness in
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the control of interfaces between operating and administrative control
procedures and will be reviewed during a subsequent inspection (85-09-08).
7.1 Radwaste Preparation Procedures
The licensee's procedures for collecting, processing and preparing
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radwaste for shipment to authorized disposal sites were reviewed and
discussed with the licensee. Within the scope of this review, the
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following violation was noted:
Technical Specification 6.8 requires, in part, that each procedure be
reviewed by the Plant Operations Review Committee (PORC) and approved
by the Station Superintendent prior to implementation.
Contrary to these requirements, Procedure No. SS-008, " Operating
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Procedure For NUSPSC Radwaste Solidification No. 8921", Revision E,
was used to solidify evaporator bottom radwaste on three occasions
and had neither been reviewed by the PORC nor approved by the Station
Superintendent prior to its implementation in those solidifications.
On October 19, 1984, the licensee shipped 2.9 Curies of evaporator
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bottoms solidified under Procedure No.55-008. On November 15, 1984,
a second shipment of 2.2 Curies of evaporator bottoms solidified
under the procedure was made. On March 27-28, 1985, the licensee
solidified additional evaporator bottoms under the procedure. The
procedure had not been reviewed and approved on April 12, 1985.
Failure to review and approve Procedure No.55-008 prior to its implement-
ation to solidify evaporator bottoms constitutes a violation of Technical Specification 6.8. (85-09-04)
7.2 Waste Classification Procedures
Procedures for determining the waste classification under 10 CFR 61 and
providing a description of the radiological, physical and chemical
composition of radwaste shipments were reviewed. Within the scope of this
review, the following weaknesses were noted:
RAP No. 6.3-5 references several tables in Impe11/EAL Report
No. 02-0240-1172, "10 CFR 61 Compliance Program Northeast Utilities
Service Company Haddam Neck Plant", for determining scaling factors
used to correlate difficult-to-measure radionuclides to easier-to-
measure key gamma-emitting radionuclide concentrations in radwaste
shipments. However, those tables were not included in RAP No. 6.3-5.
The inspector noted that two copies of the Impell/EAL Report were
available, i.e. a preliminary and a final draft.
Since the scaling
factors are used to determine wate classification, the scaling
factors should be controlled under plant procedures.
Since neither
copy of Impell/EAL Report No. 02-0240-7771 was controlled under plant
procedures, the scaling factors used to determine waste classifica-
tion were not controlled.
Failure to control the scaling factors
under plant procedures is considered a weakness (85-09-09).
Under RAP No. 6.3-5, dose rate to curie conversion factors were used
to determine radwaste activities for Low Specific Activity (LSA)
boxes, drums, dewatered fi1*ers and solidified wastes.
Calculations
utilizing these dose rate to curie conversion factors were made for
shipments of radwastes and used to record the activities of those
shipments on shipping documents. However, records detailing the
calculations, were not available for review.
Failure to maintain
records of the calculations used to determine total shipment
activities is considered a weakness in the administrative controls
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for radwaste shipments (85-09-10).
Under SUR No. 5.6-14, a sampling and analysis program to ensure
compliance with 10 CFR Part 61 limits was maintained.
That program
monitors the Reactor Coolant System (RCS).
Increased activation
product or fission product activities in the RCS noted by the
Chemistry Section are reported to Radioactive Materials Handling
Section under SUR No. 5.6-14.
However, RAP No. 6.3-5 did not provide
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administrative controls to evoke recharacterization of waste streams
upon significant changes in the reactor coolant activity.
Failure to
provide these procedural controls constitutes a weakness in the
control of radwaste shipments (85-09-11).
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.
Within the scope of this review, the following was identified.
As stated in Paragraph 5 of this report, the licensee used package
Model No. CNSI 14-170 to ship dewatered resin on June 26, 1984.
Administrative problems associated with the selection and procurement
of this package are discussed in Paragraph 5 of this report.
In
addition, the licensee made numerous shipments of radioactive waste
to the burial site in Barnwell, SC.
The shipments were made in
55 gallon drums, 4'x4'x8 metal boxes, and NRC approved packages.
Within the scope of this review, no violations were identified.
9.
Preparation of Packages for Shipment
The licensee's program for the preparation of packages for shipment was
reviewed agair st the requirements of 49 CFR Parts 172 and 173, " Shippers-
General Requirements For Shipments And Packagings", 10 CFR 71.87, " Routine
Determinations", Procedure No. RAP 6.3-5, " Radioactive Material Manage-
ment" and Procedure No. RAP 6.3-9, "Use Of USNRC Certified Radioactive
Material Packages".
The licensee's performance relative to these criteria was determined by
discussion with the Radioactive Materials Handling Supervisor, the Health
Physics Supervisor, and by reviewing appropriate documents.
Within the scope of this review, the following was identified.
During the period June-December 1984 the licensee made several ship-
ments of radioactive waste to the burial site in Bronwell, SC using
various NRC approved packages. The Certificates of Compliance for
these packages were reviewed by the inspector to verify licensee
compliance.
Within the scope of this review, no violations were identified.
m
.
.
14
10.0 Delivery Of Packages To Carriers
The licensee's procedures for delivering packages to carriers were
reviewed against criteria provided in:
- 10 CFR 71.5(a)(1)(iii), " Placarding";
- 10 CFR 71.5(a)(1)(vi), " Shipping Manifest";
- 10 CFR 20.311(b), " Shipping Manifest";
- 10 CFR 20.311(c), " 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 licensee representatives (denoted in Paragraph
1) at the conclusion of the inspection. The inspector summarized the
scope of the inspection and findings.
The inspector informed the plant
management that the Corporate QA program and Corporate staff involvement
in the packaging and transportation of radwaste will be examined during
an upcoming inspection at Millstone Station, inspection No. 50-245/85-11
and 50-336/85-14 during the period of April 22-26, 1985.
Additional
findings related to this area will be discussed on April 26, 1985 at
Millstone Station.
At no time during this inspection was written material provided to the
licensee by the inspector. No information exempt from disclosure under
10 CFR 2.790 is discussed in this report.