ML20140J472

Insp Rept 50-213/86-04 on 860310-14.Violation Noted:Failure to Provide Quantitative or Qualitative Acceptance Criteria, to Identify Radionuclide Quantity,Identity & Total Activity on Waste Manifests & Improper Certification

ML20140J472
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/27/1986
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140J454	List: ML20140J450 ML20140J472
References
50-213-86-04, 50-213-86-4, IEB-79-19, NUDOCS 8604040341
Download: ML20140J472 (14)

See also: IR 05000213/1986004

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-213/86-04

Docket No. 50-213

License No. DPR-61 Priority -- Category C

Licensee: Connecticut Yankee Atomic Power Company

P. O. Box 270

Hartford, Connecticut 06101

Facility Name: Haddam Neck Power Station

Inspection At: Haddam Neck, Connecticut l

Inspection Conducted: March 10-14, 1986

Inspectors: Ao [ fe

H.J. Bicehouse, Ra Wati&n Specialist

.3 T7 [,

dat e

Approved by: [A). Mf[

iC Pasciak, Chief

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3\11 f(

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date

Effluents Radiation Protection Section

Inspection Summary: Inspection March 10-14, 1986, (Report No. 50-213/86-04)

Areas Inspected: Routine unannounced safety inspection by a regionally-based

inspector of the licensee's radioactive waste preparation, packaging'and

shipping program including: previously identified items, management controls,

quality assurance / quality control and implementation of the program.

Results: Four apparent violations were identified (all relating to omissions

of Iron-55 in shipment documents) including failure to provide quantitative or

qualitative acceptance criteria (Detail 4.2), failure to indicate the radio-

nuclide identity, quantity and total activity on waste manifests (Detail 6.1),

improper certification on waste manifests (Detail 6.1), and failure to name

Iron-55 and include its activity on shipping papers (Detail 6.4).

B604040341 86032723

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DETAILS

1.0 Personnel Contacted

1.1 Licensee Personnel

• R. H. Graves, Station Superintendent

• J. E. Beauchamp, QA/QC Supervisor

• G. H. Bouchard, Station Services Superintendent

• H. Clow, Health Physics Supervisor

• R. E. Haight, Radioactive Material Handling Supervisor

• W. Heinig, Quality Assurance Engineering Specialist

• J. J. LaPlatney, Station Services Staff Assistant

Other licensee personnel were contacted or interviewed during this

inspection.

1.2 NRC Personnel

7 *P. D. Swetland, Senior Re~sident Inspector

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• S. M. Pindale, Resident Inspector

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• Attended the exit interview on March 14, 1986.

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2.0~ Purpose

The purpose of this routine safety inspection was to review the

licensee's program with respect to the following areas:

=Previously Identified Items;

• Management Controls;

• Quality Assurance (QA)/ Quality Control (QC); and

• Implementation of the Radwaste Preparation, Packaging and Shipping

Program.

i 3.0 Status of Previously Identified Items

3.1 (Closed) Unresolved (50-213/83-02-01) Audit not done. The annual

audit for radwaste shipments (Audit No. A-60197, "Radwaste Shipment")

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was completed in November 1983. This item is closed.

3.2 (Closed) Violation (50-213/84-11-01) Failure to follow procedures.

The licensee's actions (as described in the letter from J. F. Opeka,

Vice President to T. T. Martin, NRC-Region I, dated 09/05/84) were

reviewed. Receipt inspections of High Integrity Containers (HIC)

were performed on a sample of those containers reviewed during the

inspection. The licensee appeared to be implementing actions as

described in the licensee's letter. This item is closed.

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3.3 (Closed) Violation (50-213/84-11-02) Failure to conduct a QC Program

regarding 10 CFR 20.311(d)(3). The licensee's actions (described in

the 9/5/84 letter) were reviewed. Additional actions

(including hold points in waste processing procedures) have'been

implemented. This item is closed.

3.4 (Closed) Deviation (50-213/84-11-03) Failure to document training

regarding IE Bulletin No. 79-19. Documentation of training on

radioactive waste shipping, packaging and transportation was

reviewed by the Resident. Inspector and appeared to be adequate. A

formal program (described in Detail 4.3) has been developed and

implemented. This item is closed.

3.5 (Closed) Followup Item (50-213/85-09-01) Failure to adequately train

QC Inspectors. The licensee presented a course on radwaste

preparation, packaging and shipping requirements to QC inspectors in

December 1985. This item is closed.

3.5 (Closed). Followup Item (50-213/85-09-02) Failure to identify Package

14-170 as an unapproved package designation. Licensee procedures

and records were reviewed to determine if corrective actions ensured

that shipping package designation corresponded to Certificate of

Compliance (CoC) designations prior to shipment. The licensee

appeared to have instituted adequate controls and quality control

checks to ensure that shipping documents accurately reflected proper

shipping container designations. This item is closed.

3.7 (Closed) Followup Item (50-213/85-09-03) Lack of QC involvement in

10 CFR 61.55 and 61.56. Licensee procedures and records related to

vendor-supplied radwaste solidification services were reviewed. QC

inspection hold points (at appropriate steps in the procedure) were

provided in the eight procedures reviewed and records indicated that

QC inspections were completed at those holdpoints. This item is

closed.

3.8 (Closed) Violation (50-213/85-09-04) Failure'to follow procedures

for receipt inspections and failure to review / approve procedures.

Actions described in the licensee's letter (dated July 26, 1985) were

reviewed. The licensee modified receipt procedures to ensure that

appropriate QC inspections were performed. Vendor procedures

governing operation and process control of radwaste solidification

units were reviewed and approved as controlled plant procedures.

Review of records related to receipt of vendor-supplied solidifica-

tion equipment showed that receipt inspections had been performed.

This item is closed.

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3.9 (0 pen) Followup Item (50-213/85-09-04) QA Procedures will be revised

to reflect QA Topical Report. A draft corporate procedure, (i.e.

Nuclear Engineering and Operations Procedure 6.07, " Quality Assurance

and Quality Control in Station Radioactive Material Processing,

Classification Packaging and Transportation"), was reviewed and it

appeared to be generally adequate to address concerns raised in this

item. However, the procedure had not been approved and implemented

at the time of the inspection. This item will remain open pending

final revision, approval and implementation of the' procedure.

3.10 (Closed) Followup Item (50-213/85-09-06) Review QA monitoring ,

frequencies. The applications of QA monitoring procedures to the

radwaste transportation area were reviewed and discussed with the

licensee's QA organization. The inspector noted that the frequency

of QA monitoring in the area had not increased. However, increased

QA surveillance activities were noted. The licensee appeared to be

reviewing procedural adherence by the radwaste shipping and QC

groups on a more frequent basis (i.e. approximately once per

quarter). This item is closed.

3.11 (Closed) Followup. Item (50-213/85-09-07) Review RWTRG Report. The

licensee's Radioactive Waste Transportation Review Group (RWTRG)

Report, action items and their completion were reviewed. The

licensee appeared to have adopted suggested corrective actions in

the RWTRG Report. This item is closed.

3.12 (Closed) Followup Item (50-213/85-09-08) Review Administrative

4 Control Procedure (ACP) 1.2-13.5 for inclusion of correct sections

4 of Procedure RAP 6.3-5. ACP 1.2-13.5, " Entry and Exit From Station

of Transporter for Nuclear By-Products Material (Rad Waste),"

Revision 10 (10/18/85) was reviewed and determined to contain

correct references to implementing procedures. This item is

closed.

3.13 (Closed) Followup Item (50-213/85-09-09) Scaling factors were not

controlled. Radiation Protection Procedure (RAP) 6.3-5,

" Radioactive Material Management," Revision 27 (12/26/85)

was reviewed to determine if scaling factors for difficult to

measure radionuclides from the licensee's vendor analysis of

radwaste streams had been included. Attachment W to the procedure

provided the 1985 scaling factors. This item is closed.

3.14 (Closed) Followup Item (50-213/85-09-10) Licensee did not maintain

record of calculations. In the licensee's letter (dated 7/26/85),

the licensee committed to maintaining a file for calculations utiliz-

ing dose rate to curie conversion factors. The licensee had

established a file containing memoranda from the licensee's corporate

Radiological Assessment Branch (RAB) providing dose rate to curie

conversion factors. However, the file did not contain the actual

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calculations'for the radwaste shipments covered by the RAB memoranda

(see related item, Detail- 6.1). This item is closed administra-

tively.

3.15 (Closed) Followup Item (50-213/85-09-11) Lack of administrative ,

controls to prevent' shipments. Surveillance Procedure (SUR) 5.6-14,

(" Sampling Guidelines for~10 CFR 61 Compliance, Revision 4, 3/6/86");

was reviewed. Guidance was provided in the surveillance procedure

to evoke recharacterization of waste streams if significant (i.e.

factor of 10 or more) changes in reactor coolant activity were noted.

This item is closed.

4.0 Management Controls

The licensee's management controls were reviewed to determine if clear

designations of responsibilities and controlled instructions were

provided for radwaste processing, packaging and shipping activities.

Criteria provided in the licensee's Technical Specifications, Updated

Final Safety Analysis Report and NRC Regulations were used in this review.

4.1 Organization

The organizational structure of the licensee's Radioactive Materials

Handling _(RMH) group was reviewed. The RMH group (in the Radiation

Protection Department) is supervised by the RMH Supervisor. The RMH

Supervisor reports to the Radiation Protection Supervisor who in

turn reports to the Health Physics Supervisor. The responsibilities

of the RMH group were clearly described in RAP 6.3-5 with regards to

receipt, use, storage, packaging, loading and shipping solid

radwaste.

Within the scope of this review, no violations were noted.

4.2 Procedures

The licensee's procedures for preparation, classification, packaging

and shipping radwastes were reviewed relative to criteria provided

in:

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10 CFR 20.311, 71.5 and 71.12;

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Technical Specification'6.8, " Procedures;"

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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures

and Drawings;"

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NRC Regulatory Guide 1.33, " Quality Assurance Program

Requirements (Operation)";-and

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ANSI N18.7-1976, " Administrative Controls and Quality Assurance

for The Operational Phase of Nuclear Power Plants."

The following procedures were reviewed for conformance to the

criteria above and discussed with the members of the RMH Group:

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ACP 1.2-13.5, " Entry and Exit from Station of Transporter for

Nuclear By-Products Material (Rad Waste)", Revision 10

(10/18/85);

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RAP 6.3-5, " Radioactive Material Management," Revision 27

(12/26/85);

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RAP 6.3-9, "Use of USNRC Certified Radioactive Material

Packages," Revision 2 (10/24/85); and

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SUR 5.6-14, " Sampling Guidelines for 10 CFR Part 61

Compliance," Revision 4,(3/16/86).

Within the scope of this review, the following violation was noted:

10 CFR 50, Appendix B, Criterion V requires, in part, that

procedures include appropriate quantitative or qualitative

acceptance criteria for determining that important activities have

been satisfactorily accomplished.

Contrary to this requirement, neither ACP 1.2-13.5 nor RAP 6.3-5

provides quantitative or qualitative acceptance criteria for

verification of the identity of the radionuclides and activity

levels (i.e. curie content) of the solid radwaste shipments.

Determining the identity of the radionuclides is an important

activity since the identification affects determination of the

acceptability of radwaste for disposal in shallow land burial sites

under 10 CFR 20.311 and 10 CFR 61 and the packaging and handling of

radwaste shipments under 10 CFR 71. Determining the curie content

of solid radwaste shipments is also an important activity since it,

too, affects the determination of the acceptability of the radwaste

and its packaging'and handling requirements. (See related item in

Detail 6). Failure to provide quantitative or qualitative

acceptance criteria for the verification of the identity and curie

content of radwaste shipments constitutes an apparent violation of 10

CFR 50, Appendix.B, Criterion V. 50-213/86-04-01

4.3 Indoctrination and Training

The licensee's indoctrination and training program related to solid

radwaste preparation, packaging and shipping activities was reviewed

relative to criteria and commitments provided in the following:

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Technical Specification 6.3, " Facility Staff Qualifications;"

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Technical Specification 6.4, " Training;"

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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant

Personnel;"

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Licensee's letter W. G. Counsil to B._ H. Grier (NRC Region I)

dated 9/17/79 in response to IE Bulletin No. 79-19,

" Packaging of Low-Level Radioactive Waste for Transport and

-Burial," (8/10/79); and

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10 CFR 50, Appendix B, Criterion II, " Quality Assurance

Program."

The schedules, lesson plans and performance of the training was

reviewed for' selected members of the RMH Group and QC personnel.

The licensee provided training inhouse and vendor-supplied training

on alternate years for the personnel reviewed. Within the scope of

this review, no violations or deviations were noted.

5.0 _ Quality Assurance / Quality Control

The provisions of 10 CFR 71, Subpart H require the establishment of a QA

program for the packaging and transportation of radioactive materials. A

Commission approved QA program which satisfies the applicable criteria of

Appendix 8 to 10 CFR 50 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 the packaging and

shipment of radioactive materials.

Specific QC requirements to assure compliance with 10 CFR 61.55 and 61.56

are mandated by 10 CFR 20.311 in addition to the general QC requirements

required by 10 CFR 50, Appendix B. A process control program for. waste

solidification is required by Technical Specification 6.18, " Radioactive

Waste Treatment Systems." The implementation of QA/QC activities to the

preparation, packaging and shipment of solid radwaste was reviewed.

5.1 Radwaste Generator QC Program

The licensee's performance in the conduct of a QC program under 10

CFR 20.311(d)(3) and Technical Specification 6.18 was determined by

review of procedures for preparing radwaste shipments, examination

of records related to shipments of dewatered resins, solidified

waste liquids and dewatered filters, independent determination of

waste classification under 10 CFR 61.55 for selected shipments and

discussions with the RMH Supervisor, members of the RMH Group staff,

solidification vendor representatives and the QA/QC supervisor.

Within the scope of this review, the following items were noted:

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Samples from the licensee's dry active waste, resins, reactor

coolant, evaporator bottoms and filters were taken and sent to

a contractor for analysis. Scaling factors for determining the

activities of difficult to measure radionuclides were

determined by the contractor and provided in annual reports.

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The vendor's Process Control Program for solidification of waste

liquids was reviewed, incorporated into licensee's procedures

and implemented.

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Specific Inspection Hold Points related to dewatering and/or

solidification were provided in controlled procedures.

5.2 QC Inspection Activities

The site QC organization provides inspections of radwaste

preparation, packaging and shipping activities. The following

procedures were reviewed for appropriate inspection hold points:

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RAP 6.3-5, " Radioactive Material Management," Revision 27

(12/26/85);

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RAP 6.3-9, "Use of USNRC Certified Radioactive Material

Packages," Revision 2 (10/24/85);

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Vendor Procedure SS-001, " Process Control Program for NUSPSC

Radwaste solidification Systems," Revision I (8/16/85);

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Vendor Procedure SS-008, " Operating Procedure for NUSPSC

Radwaste Solidification System No. 8921," Revision D (3/11/85);

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Vendor Procedure SS-010, " System Setup / Removal Procedure for

NUSPSC Radwaste Solidification System No. 8921," Revision B

(10/3/84);

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Vendor Procedure SS-013, " Operating Procedure for NUSPSC

Radwaste Solidification System No. 8901," Revision B (5/22/85);

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Vendor Procedure SS-014, " Process Control Program for NUSPSC

Radwaste Solidification Systems - Class A, Unstable Wastes,"

Revision C (5/23/85);

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Vendor Procedures SS-015, " System Setup / Removal Procedure for

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NUSPSC Radwaste Solidification System No. 8901," Revision A

(2/12/85);

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Vendor Procedure SS-022, " Operating Procedure for NUSPSC

Radwaste Solidification System No. 8807," Revision A

(11/16/85); and

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Verdor Procedure SS-021, " System Setup / Removal Procedure for

NUSPSC Radwaste Solidification System No. 8807," Revision A

(11/16/85).

Representatives of the site QC organization were interviewed to-

determine the criteria by which successful completion of selected

Inspection Hold Points was determined. The inspector noted that

the site QC organization did not independently verify that the

identity and activities of the various radionuclides in the shipping

papers vere correct. The inspector also noted that peer review by

qualified members of the Radiation Protection staff of the

identities and activities of the shipped radionuclides wasn't

routinely completed.

5.3 QA Surveillance Activities

The site QA organization provides periodic surveillance of solid

radwaste preparation, packaging and shipping activities. As noted

in Detail 3.10, surveillance frequencies had been increased by the

licensee. However, QA surveillance activities did not include

independent verification of the identities and activities of the

radionuclides as presented in the shipping. papers.

5.4 Audits

The licensee's program for audits of radwaste . preparation,

classification, packaging and shipping activities was reviewed.

Audit No. A60221 "Radwaste Shipment at Connecticut Yankee Power

Station," (3/20 - 6/6/85) was reviewed. The audit was performed to

verify the station's implementation of 10 CFR 20, 61, 71 and 49 CFR

requirements. The audit was conducted by two QA auditors and a

qualified technical specialist. The inspector noted that audit

findings had been evaluated by licensee management (as required by 10

CFR 20.311(d)(3)). The audit failed to note the problem with Iron-55

identification and quantification in shipping and waste manifests

(See Detail 6).

.6.0 Impiementation

During 1985-86, the licensee made 29 shipments of solid radwaste. Those

radwaste shipments were reviewed against criteria provided in:

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10 CFR 20.311, 61.55 and 61.56;

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10 CFR 71;

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49 CFR 170-189; and

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Station Technical Specifications and Procedures.

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The Itcansee reported that the Agreement State in which the radwaste

shipments were buried had not issued any violations or warnings for the

radwaste shipments received.

6.1 Vaste Generator Requirements

The following waste generator requirements were reviewed and

discussed with the licensee:

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Waste Panifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);

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Waste Classification under 10 CFR 20.311(d)(1);

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Waste form and Characterization under 10 CFR 20.311(d)(1) and

10 CFR 61.56;

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Waste shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR

61.55;

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Tracking of waste shipments under 10 CFR 20.311(d), (e), (f)

and (b); and

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Disposal site license conditions.

Within the scope of this review, the following violations were noted:

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10 CFR 20.311(b)' requires, in part, that the manifest

accompanying radwaste shipments indicate as completely as

practicable the radionuclide identity and quantity and the

total radioactivity of the shipments.

Contrary to this requirement, the licensee failed to identify

the radionuclide Iron-55 and its activity on the following

radwaste shipment manifests:

Total Listed Activity

Shipment No. Descript (curies) Date

W-85-1 Dewatered resin 3.332 3/5/85

W-85-2 Dewatered filters 7,599 5/14/85

W-85-3 Cewatered filters 19.18 5/28/85

W-85-5 Compacted dry 0.747 2/20/85

activ'e waste

W-85-8 Solidified ligulds 1.123 10/4/85

W-85-9 Dewatered resin 8.783 10/22/85

W-85-10 Compacted dry 0,6319 10/10/85

active waste

W-85-11 Solidified liquids 0.1161 8/28/85

W-85-12 Dewatered resins 134.49 9/18/85

W-85-13 Solidified liquids 3.978 10/4/85

W-85-15 Solidified liquids 1.460 10/25/85

W-85-18 Dewatered resin 16.061 12/30/85

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Total Listed Activity

Shipment No. Descript (curies) Date

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W-85-19 Dewatered resin. 2.192 12/20/85

.W-86-5 Solidified liquid 0.2041 2/13/86

W-86-6 Solidified liquid 5.305 2/25/86

W-86-8 Solidified liquid 1.741 3/11/86

W-86-9 Solidified liquid 2.5793 3/13/86

W-86-11 Solidified liquid 0.6091 2/10/86

The licensee's vendor analyses of various radwaste streams within

the plant identified the presence of Iron-55 and provided the

following scaling factors relative to cobalt-60 activity:

Waste Stream Analysed Iron-55/ Cobalt-60 ratio

Reactor coolant-liquid 1.4

Resin 1.9

Filter 6.7

Dry active waste 1.5

Evaporator bottoms 1.3

The licensee determines the percent isotopic composition for the

energetic gamma emitting radionuclides (e.g. cobalt-60) and a dose

rate to curie conversion factor for the waste shipment container

geometry based on gamma spectroscopic analysis and accepted computer

programs. Calculations-of the activity of hard-to-identify

radionuclides (e.g. Iron-55) are then made using the scaling factors

provided in the vendor's analytical report. For example, licensee's

shipment no. W-85-12 contained 5.16%. cobalt-60 by gamma

spectroscopic analysis. The scaling factor for Iron-55 in dewatered

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resins is 1.9. The calculated total activity due to Iron-55 in the

shipment would be found by multiplying the shipment's total activity

by the fraction due to Cobalt-60 activity and the appropriate

scaling factor, vis. (0.0516) (134.49 curies) (1.9) = 13.18 curies

additional activity due to Iron-55. However, the licensee failed to

list Iron-55 as a constituent'of the shipments listed above and did

not conduct the calculations as shown above to determine the

activity due to Iron-55 in each shipment.

The inspector calculated the estimated activity due to Iron-55 in

each of shipments below:

Total Activity Percent Scaling Activity from

Shipment No. (Curies) Cobalt-60 Factor Iron-55 (Curies)

W-85-1 3.332 71.5 1.9 4.52

W-85-2 7.599 11.0 6.7 5.60

W-85-3 19.18 13.3 6.7 17.09

W-85-5 0.747 24.1 1.5 0.27

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Total Activity. Percent Scaling Activity from

Shipment No. (Curies) Cobalt-60 Factor Iron-55 (Curies) l

W-85-8 1.123 47.98 1.3 0.70

W-85-9 8.783 8.30 1.9 1.38

W-85-10 0.6319 28.8 1.5 0.27

W-85-11 0.1161 2.72 1.3 0'.004

W-85-12 134.49 5.16 1.9 13.18

-W-85-13 3.978 57.27 1.3 2.96

W-85-15 1.460 12.03 1.3 0.22

W *5-13 16.061 0.294 1.9- 0.0897

W-85-19 2.192 0.691 1.9 0.0287

W-86-5 0.2041 21.03 1.3 0.0558

W-86-6 5.305 14.26 1.3 0.983

W-86-8 1.741 23.34 1.3 0.528

W-86-9 2.5793 27.57 1.3 0.924

W-86-11 0.6091 15.17 1.3 0.120

Since Iron-55 was not identified and its activity determined for

each shipment, the manifests accompanying each shipment contained

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incorrect total activities for those shipments. Failure to identify

Iron-55, determine its activity in each shipment and include the

radionuclide in the total radioactivity of.the shipment constitutes

an apparent violation of 10 CFR 20.311(b). 50-213/86-04-02

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10 CFR 20.311(c) requires, in part, certification by the waste

generator that the transported materials are properly

described. Contrary to this requirement, the licensee

certified that each of the radwaste shipments above were

properly described when the identity of one of the

radionuclides was missing and the activity due to that

radionuclide was not identified and included in the total

activity of the transported materials. Certification that each

of the waste shipments were' properly described when they were

not constitutes an apparent violation of 10 CFR 20.311(c).

50-213/86-04-03

6.2 Procurement and Selection of Packaging

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 Department of Transportation (00T)

requirements of.49 CFR 173, " Shippers - General Requirements for

Shipments and Packaging."

The licensee's performance relative to the criteria was determined

by interviews of the RMH Supervisor and members of his staff,

examinations of documents, procedures and shipping records and

observations during plant tours.

Within the scope of this review, no violations were noted.

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6.3 Preparation of Packages for Shipment

The licensee's program for preparing packages for shipment was

reviewed relative to the requirements of 49 CFR Parts 172 and 173,

10 CFR 71.87 and Technical Specifications.

The. licensee's performance relative to the criteria was determined

by interviews of the RMH Supervisor and members of his staff,

examination of procedures,~ shipping records and other documents, and

observations during plant tours of handling, storage and loading

areas and licensee preparations for shipment of a cask.

Within the scope of this review, the following item was noted:

On 9/11/85, the licensee was installing a high integr'ty

container (HIC) in the " Resin Pit" area and connecting lines to the

container for dewatering. An Auxiliary Operator, a Radwaste

Technician and a Health Physics Technician were assigned to the

operation working under Radiation Work Permit No. 8502183. The

" Resin Pit" area was a high radiation area with radiation fields

ranging from 100 millirem per. hour to 18,000 millirem per hour in

the work area. The fitting on the HIC for the dewatering leg was a

2 inch fitting while the line used for_the dewatering contained a lh

inch fitting. The Radwaste Technician was unable to make the

connections for the dewatering and remained in the high radiation

area attempting to connect the 2 inch fitting to the 1h inch line.

The low-range, (i.e. 0-200 millirem), dosimeter for the Radwaste

Technician was noted to be "offscale". Examination of his high

range dosimeter indicated an exposure of approximately 950 millirems

during the Radwaste Technician's attempts to connect the dewatering

line.

The licensee's investigation and resolution of the problems

encountered during the entry were reviewed. This area will be

further reviewed during a subsequent inspection. 50-213/86-04-05

6.4 Delivery of Packages to Carriers

The licensee's program for delivering packages to carriers was

reviewed relative to criteria provided in:

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10 CFR 71.5 (a) (1) (iii), " Placarding;"

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10 CFR 71.5 (a) (1) (vi), " Shipping Manifests:d

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10 CFR 71.5 (a) (1) (iv), "Public Highway - 49 CFR Part 177;"

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licensee's Technical Specifications.and applicable procedures.

The licensee's performance relative to the criteria was determined

by review of shipping records for radwaste shipments in 1985-86,

discussions with cognizant licensee personnel and ubservation of

preparations for a radwaste shipment.

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Within the scope of this review, the following apparent violation was

noted:

\

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10 CFR 71.5(a)(1)(vi) requires preparation of shipping papers

in accordance with 49 CFR 172, Subpart C. 49 CFR 172.203(d)(i)

requires the name of each radionuclide in the shipment and 49

CFR 172.203(d)(iii) requires the activity of each package in

the shipment be included in the shipping papers.

Contrary to the requirements, the licensee failed to include Iron-55

and the activity resulting from that radionuclide in the shipping

papers associated with the radwaste shipments in Detail 6.1.

Failure to name Iron-55 and include the activity due to that

radionuclide in the shipping papers associated with the radwaste

shipments in Detail 6.1 constitutes an apparent violation of 10 CFR

71.5 (a) (1) (vi). 50-213/86-04-04

7.0 Exit Interview ,

The inspector met with the licensee representativeshenojed,in i

Paragraph 1) at the conclusion of the inspection on Kirch 14,4986. The

inspector summarized the scope of the inspection and findings asu ,

described in this report. \

The licensee's representative acknowledged the findings r' elated to the

omission of Iron-55 in the waste manifests and shipping papers and

provided the following corrective actions in response to the finding:

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Before the next radwaste shipment, the licensee will audit radwaste

shipments 1984-86 to determine which shipments had incorrect' waste

manifests and shipping papers due to the omisstor, of Iron-55. ,

.

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Before the next radwaste shipment, the licensee will notify the DOT

and the State of South Carolina of the results of the audit.

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Before the next radwaste shipment, the licensee will revise RAP ,

6.3-5 to include Iron-55 and to require an independent review of the

identities and activities associated with each shipment.

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The licensee will provide corrected waste manifests and shipping

papers to the DOT and the State of South Carolina.

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The' licensee will update the Semiannual Radioactive Effluent and

Waste Disposal Reports to include activities due to Iron-55.

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.

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