IR 05000245/1985011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/85-11 & 50-336/85-14,including Upgrading Radwaste Processing & Shipping Program

ML20134E306
Person / Time
Site:	Millstone
Issue date:	08/14/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Opeka J NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8508200144
Download: ML20134E306 (2)

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AUG 141985 Docket Nos. 50-245 License Nos. DPR-21 50-336 DPR-65 Northeast Nuclear Energy Company ATTN: Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P.O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:

Subject: Combined Inspection 50-245/85-11 and 50-336/85-14 Your letter of July 19, 1985, in response to our letter dated June 18, 1985, informed us of your corrective and preventive actions for upgrading your radioactive waste processing and shipping progra These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate

Sincerely, gy a m .: " i Thomas T. Martin, Directo Division of Radiation Safety and Safeguards cc:

E. J. Mroczka, Vice President, Nuclear Operations W. D. Romberg, Station Superintendent D. O. Nordquist, Manager of Quality Assurance R. T. Laudenat, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Connecticut 8508200144 B50814 PDR ADOCK 05000245 G PDR OFFICIAL RECORD COPY RL MILL 85-11 - 0001. /03/85 $

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o Northeast Nuclear Energy Company 2 bcc:

Region I Docket Room (with concurrences)

Sonie, 0;:r=Hons Office; DRP Section Chief

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P.o. Box 270 HARTFORD. CONNECTICUT 06141-0270 k L " " " ",,' [,',',7,,7, ,'"~'.".,*.

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(203) 665-5000

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July 19, 1985 Ibcket Nos. 50-245 50-336 A05002 Dr. 'Ihmas E. Murley Regional Administrator Region I U.S. Nuclear Regulatory Cbmnission 631 Park Avenue King of Prussia, PA 19406

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Reference: (1) letter, 'Ihamas E. Murley to John F. Opeka, dated June 18, 1985, Inspection Report Nos. 50-245/85-11 and 5 b366/85-1 Gentlemen:

Millstone Nuclear Power Station, Unit Nos. 1 and 2 Response to I&E Inspection Nos. 50-245/85-11 and 50-336/85-14

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Pursuant to the provisions of Section 2.201 of the NRC's Rules of Practice, Part 2, Title 10 Code of Federal Regulations, this report is subnitted in reply to Reference (1).

Reference (1) informed the Northeast Nuclear Energy Cmpany (NNECo) of '

a Severity Level III violation as a result of an item of non-cmpliance noted during an inspection conducted by a representative of _ _

the South Carolina &partment of Health and Enviromental (bntrol on a tractor-trailer containing licensed materia , ..

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k VIOLATION 4 As a result of the inspection conducted on March 11, 1985, by a '

representative of the South Carolina Department of Health and Environ-mental Cbntrol of a shipnent of licensed material sent frm your facility in Waterford, Connecticut, on or about March 8, 1985 and in accordance with the NRC Enforcement Policy (10CFR2, Appendix C) the following violation was identifie .

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-2-10CFR71.45, " External Radiation Standards For All Packages," states that a package must be designed and prepared for shipnent so that the radiation level does not exceed 200 millirem per hour at any point on the external surface of the package. The regulation also states that the radiation level at any point on the external surface of the package may exceed 200 millirem per hour but the shipnent must be made in a closed transport vehicl Contrary to the above, on March 11, 1985, a waste shipnent containing 564 millicuries of licensed material was transported to the Chem Nuclear Systems, Inc. burial site at Barnwell, South Carolina on an open, flatbed tractor trailer, and one package (Package 2b. 84-1114-1)

was found to have a radiation level of 380 millirem per hour on the external surface of the packag RESPONSE The Radioactive Materials Handling Department has been reorganized with the Radioactive Material Handling Supervisor now reporting to the Health Physics Supervisor. A procedure RW60012/260012/360012,

" Packing Non-Campactible LSA Containers" has been written and imple- ,

mented. This procedure precludes any item greater than 160 mr/hr frcm being placed into a non-compactible LSA box. Also, LSA non-ccupactible boxes are inspected by Station Management and Quality Control prior to their being seale The above action was implemented July 1, 1985. This action should preclude this type of incident frca reoccurring.-

Reference (1) also informed the Northeast Nuclear Energy Cbnpany (NNECo) of a Severity Level IV Violation as a result of an item of non-ccmpliance noted during inspection on April 15-19, 198 VIOIATION Technical Specification 6.8.1 requires, in part, that written *

procedures be implemented. Administrative Control Procedure N ACP-OA-4.04, " Instructions for Packing, Shipping, Receiving, Storage ~

and Handling," requires, in part, that Category I materials, equignent, and parts shipped to the site be inspected by the Quality Assurance Organization upon receipt. Category I Items and'Servlees in the licensee's Quality Assurance 7bpical Peport include those associ-ated with the preparation of radioactive wastes for shipment. .

Cbntrary to the above, prior to August 27, 1984, a vendor-supplied radwaste solidification system was received at the Millstone site, used in the preparation of thermal shield radioactive waste shipnent on or about August 27, 1984, November 2, 1984 and December 18, 1984 and receipt' inspections on this system were not performe _ _ _ _ _ _ _ . - . _ _ _ - . _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ __

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-3-RESPONSE Administrative Control Procedure ACP 2.01A, " Radioactive Waste Packaging and Shipping M Program" has been written. This procedure describes how and to what extent the CA program applies to the preparation of radioactive wastes for shipnent. In accordance with this procedure services performed on site by vendors for use in radioactive shipment preparation and transport will be controlled by application of the approved NNEOo Quality Assurance Program. This action will be completed by August 1, 198 Reference (1) also identified nine areas of weaknesses during the inspection held on April 15-19, 198 WEAKNESS-1 Lack of attention to technical detail was noted in several shipnents of licensed materials, e.g. incorrect contact dose rates, incorrect recipient license, and failure to address conditions of Certificates of Omplianc .

RESPONSE Radioactive shipnents are being reviewed by several levels of Millstone management. In addition, attention to technical detail was reerphasized to all department personnel. This action should preclude this inattention to technical detail from recurrin .~

WEAKNESS-2 Procedures lacked step-by-step instructions in the degree of: detail necessary to perform the activity and acceptance criteria against which success or failure of an activity could be judge RESPONSE \

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All Radwaste Procedures are being reviewed and rewritten as necessary to incorporate step-by-step instructions. This will be ccanpleted by August 1, 198 WEAKNESS-3 4h Apparent lack of managenent oversight of packaging and shipping activities, e.g. inadequate supervision of packaging and transportation activities during the absence of the Radioactive '

Material Handling Supervisor; inactive Radioactive Review Ckunittee; the Radiological Services Supervisor did not examine radioactive materials transportation records and logs as requir.ed by the procedure .

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-4-RESPONSE Radioactive shipnents are being reviewed by several levels of management at Millstone. Radwaste activities are being monitored by the Health Physics Supervisor and the Radiological Services Superviso We Health Physics Supervisor is now the responsible person in the absence of the Radioactive Material Handling Superviso We Radf.oactive Review (bmnittee has been reinstated. A meeting was held d Ping June 1985 to discuss current radwaste problems and to make reccamerdations to the Vice President Nuclear Operations. The above actions were implemented July 1,1985 and should preclude this finding frca recurrin WEAKNESS-4 Ouality Assurance Auditor lacked technical expertise in shipping-related area RESPONSE Corporate Quality Assurance Inspectors assigned to perform audits in radioactive transportation area will be trained and will have the appropriate technical expertise to perform the audits. This will be coupleted prior to the next Radwaste Audi WEAKNESS-5 -

Additional training was needed for technicians acting in upgt'ded a position RESPONSE .

This Senior Radiation Protection Technician no longer asstnes the ..

duties of the Radioactive Materials Handing Supervisor (BMHS) in the latter's absence. The Health Physics Supervisor assumes the duties of _ ..

the BMHS. Radwaste Technicians and Health Physics Technicians acting in upgraded positions will be given specific instructions as to, their responsibilities and authority. These actions will be implement'ed by -

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WEAKNESS-6' ,

The Ouality Control Program was limited in scope with regard to the requirements of 10CFR61.55 and 10CFR61.5 RESPONSE

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The OC Program scope will be expanded to include the entire process and operatio .

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-5-WEAKNESS-7 Petrieval of shipnent records was difficul RESPONSE Radioactive shipnent records as of 1 July 1985, are being stored as a package. Ebture retrievals will be accanplished with the entire shipping package being made availabl WEAKNESS-8 Corporate Quality Assurance Implementing Procedures did not reflect transport packages as Category I Item as established by the M Tbpical Repor RESPONSE s

I ACP 2.01, "@ Boundary Program" has been revised to indicate that 1 itens and services associated with radioactive waste packaging and transportation are considered Category I m. ACP 2.10A, " Radioactive Waste Packaging and Shipping @ Program" has been written. Wis procedure describes how and to what extent the m Program applies to the preparation and shipnent of radioactive materials. E is procedure reflects the m Tbpical Peport requirements. Rese procedures will be I effective by August 1, 198 WEAKNESS-9 -

Infrequent @ monitoring of radioactive materials packaging and transportation activitie /

RESPONSE We % Department will expand the scope and frequency of the monitoring program for radioactive materials packaging and ,

transportation activitie .

Very truly yours, N \%.

• e NORMEAST NUCLEAR ENERGY COMPANY ,

b WF. Opekd Senior Vice President

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