ML20195C171
| ML20195C171 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/20/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8605300097 | |
| Download: ML20195C171 (8) | |
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'Af Teiephone (412) sea-sooo Nuclear Group ge May 20, 1986 4
77 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Thomas T. Martin, Director Division of Radiation Safety and Safeguards Region 1
631LPark Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 86-05 Gentlemen:
In response to your letter of April-21, 1986, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced inspection report.
Your letter requested that we describe the actions taken and
- planned to improve management control of the transportation program to prevent. such violations in the future.
Our own assessment of our transportation program confirms your inspector's opinion that consolidation of responsibilities related to all aspects of the transportation
- program, except Quality Assurance and Quality Control functions, be assigned to a single individual and department fully cognizant of all the requirements of the program.
Therefore program, procedure and organizational changes will be made by August 31, 1986
. which will-assign total responsibility for the transportation program to the Radiological Controls Department.
The individual assigned responsibility for the transportation program will be cognizant of its requirements.
- Further, we have already reviewed the applicable waste packaging, handling and transportation procedures to upgrade them to acceptable quality.
Our further review and improvement of-these procedures will be ongoing.
Our-review of the four (4) violations cited leads us to the conclusion that the circumstances cited in Violations B and D do not represent a
violation of NRC regulations.
The bases for our opinion is included in the attached Reply to Notice of Violation.
8605300097 860520 gDR ADOCM 05000334-PDR
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B;hvar Valley Power Station, Unit No. 1
- Dock 3t No. 50-334, Licensa No. DPR-66 Inspection Report 86-05 Page 2 If you have any questions concerning this
- response, please contact my office.
Very tr y yours, J. Carey Vice President, Nuclear
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Attachment cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U.
S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261
DUQUESNE LIGHT COMPANY scaver Valley power Station Unit No.1 Reply to Natige of Violation Inspection 86-05 Letter dated April 21, 1986
'[Ip@gCN A '(Severity Level IV; Supplement V) 4 l
Dy e,ription of,Violati_oj (S6-05-01) 10 CFR 7L,5 prohibits delivery of licensed material to a carrier'for transport unless the licensee complie's with applicable regulations of th9 Department of TransportatJon in 49 CFR Purts 170-189.
49 CFR 173.425 (b)(1).
" Transport requirements for low specific activity (LSA) radicactive materials", rGquires that packaggd shipments of LSA material cor.hioned as exclusive uce bo packaged in strong, tight packages so that there will be no leakage of radioactive materici Lnd r conditions norfnally incident to transportation.
Contrary to the above2, on Octobcr 17, 1985, twQ 5S-gallon steel drums (Drums No, 14 and 24) containing low specific act(Vity material were consigned to a
carrier for exclusive use to transport to Quad' rec Corf> oration in Oak
- Ridge, Tonnessec, and the drums were not strong and tighte Specifically, Drum No. 14, containing 0.021 millicuries of radioactive
- material, had four holes, approximately 1/4 inch in
- diameter, tha.t penetrated to the inside of the barrel and were located about one l'ach below the barrel lid locking ring.
Drum No.
- 24. was punctursd
.o n the bottom, and the punctures consisted o,f two "sicshes"
.about three inches long by 1/4 inch wide, which had been coveied with yellow tape.
corrective Action _Takeh To ensure the packages in all types of radioactivs material shipments are appropriately inspected.
Radcon Procedure 3.29, Inspection of Radioactive 61aterial Pagkaging Prior to.Sh;pment, was developed and implemented.
This procedure provides a format (Inspection Record) for documenting package inspections When checklists, required for specific types of packages (e.'g. caska) are not apOllcable.
The existing inspector requireraent.s have been uppruded as a result of l
implementing the above referensed proceduro.
Action Taken to Eroven* Recurrence The above referenced proceduto will be
- utilized, and revised as i
necessary, to avoid further violAtior_s.
Date of Fall Cdnpliahce We are in full compilanch at this tima.
Radcon Procedure 3.29, Inspection of Radicactive material PActaging Prior to Shipment, w&s implemented in February 1986.
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R; ply tc Notica of Violction Inipection 86-05
'Lstt6r dated April 21, 1986 Pago 2 e
VIOLAT[dN B,(Severity Level IV; Supplement V)
Dyscriptian of violation (86-05-02) 10 CPR 71.101(b) requires each 1.icensee to establish 3 quality ossurance program for
- packages, 10 CPR 71.101(f) states that a Commission approved quality assurahcc program that saticfies the cppllOahle criteria of Appendix 8,
Phrt
$0, of this chapter, and which is cctablished, maintained, and executed with regard to transport packages will be accepted as satisfying the requirements of paragraph (b) of this sebtion.
Criterion KVIII of Appendix D,
part 50, requires, i.n part, that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality a.9surance program and to deterro,ine the effectiveness of the prpgram.
The audits shall be performed by appropriately trhined gefronhel.
Criterion Il of Appendix B,
Part 50; requires, in part, that the
' program provide far indectrination and tra tning et personnel i
performing activitiei affecting quality as necessary lo assure that suitable proficiency is achieved and maintained, Contrary to the above, during the periou of June-July 1985, Quality Assurance Maintenance personnel conducted an audit of the Solid Waste Management
- area, and the three Auditors performing the addit had not been adequately trained to ascure that suitable proficiency was cchieved and maintained.
Specifically, although the Lead Auditor receive two to three days training in transportation activities in May
- 1984, and.the other Auditors received two days training during the period of October-November 1985, this training was not adequate in that the training material provided was too voluminous and complex tc be absorbed and retained in a two-day training program.
Admission or Denial of Violation Duquesne Light Company denies Violation 86-05-02.
Discussion We have reviewed the training provided to the auditors for the cubject QA audit of the Beaver Valley Unit 1 Radwaste Handling Program.
The purpose of the cited audit was to assess compliance with the requirements of the Radwaste Handling Program as specified in the appropriate procedures and regulatory documents.
We are committed to ANSI /ASME N45.2.23-1978.
Paragraph 2.2 states that the responsible auditing organization shall establish the audit personnel qualifications and the requirements for use of technical specialists to accomplish the auditing of the Quality Assurance programs.
L
R; ply to Notica of Violation
,Indpection 86-05 LGtter dntcd April 21, 1986 Page 3 VIOLATION B, (Continued)
Additionally, this paragraph states that personnel selected for Quality Assurance auditing assignments shall have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited.
Considering the scope of this audit, the auditor training provided to date satisfies the requirements of the Quality Assurance Program as applied to Radwaste Handling and Transport and ANSI N45.2.23-1978.
The experience level of the three (3) auditors was at least three (3) years each in Quality Assurance and a combined total of eighteen (18) years of nuclear plant experience.
The Quality Assurance Unit has a training program which qualifies and certifies personnel who conduct audits.
In the area of Radwaste Handling and Transport, additional training was provided.
Although the Notice of Violation refers to this training as too voluminous and complex to be covered in a two (2) day period, the auditing personnel who received it demonstrated their comprehension and satisfied the objectives of the course as evidenced by successful completion of the examination conducted at the completion of the course.
Additionally, the student handout, which consisted of a list of objectives, a
review summary of the Department of Transportation regulations for transport of radioactive materials, quantity tables, I.E.
Information Notice 80-32, 10CFR61, examples of BVPS paperwork, and the Burial Site Criteria was provided for future reference
-purposes.
requ'rements, the intent, scope and
?. Ster reviewing the governing i
cc.nplexity of the audit, and the auditors' experience, background and routine and specialized training, it is concluded that the auditing personnel had more than adequate and appropriate experience and training to assure that suitable proficiency was achieved and maintained.
For these
- reasons, we respectfully request that this violation be withdrawn.
L
- R; ply to Notics of Violation Ih4pection 86-05 Lstt'or detsd April 21, 1986 Page 4 VIOLATION C (Severity Level V; Supplement V)
Description of Violation (86-05-03)
Technical Specification 6.8,-Procedures, requires that procedures be established,' implemented, and. maintained.
Item E.12 of Station Administration Procedure, Chapter 6,
Radiological Control Group Administration, developed pursuant to the.above, requires that procedures be reviewed at a minimum interval of every two years, or
- after significant changes or incidents, to determine if changes to the procedures are'necessary or desirable.
-Contrary to the above, as of March 14, 1986, Procedure No. FO-OP-004,
" Dewatering Procedure for the 24-Inch Diameter Pressure Demineralizer.
Vessel Containing Ion Exchange Resins" used on at least one occasion during
- 1085, had not been reviewed since June 15, 1983, an interval of more than two years.
Corrective Actions Taken A review of procedure FO-OP-004 was performed and documented.
Actions Taken to Prevent Recurrence A
log to track the reviews of Radwaste procedures has been generated to ensure the two-year review requirement is met.
Date of Full Compliance Full compliance has been achieved at this time.
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d
RIply to Notica of Violation
- ' Ihkpection 86-05
, LGttar dated April 21, 1986 Page 4 VIOLATION C (Severity Level V; Supplement V)
Description of Violation (86-05-03)
Technical Specification 6.8, Procedures, requires that procedures be established, implemented, and maintained.
Item E.12 of Station Administration Procedure, Chapter 6,
Radiological Control Group Administration, developed pursuant to the
- above, requires that
- procedures be reviewed at a minimum interval of every two years, or after significant changes or incidents, to determine if changes to the procedures are necessary or desirable.
Contrary to the above, as of March 14, 1986, Procedure No. FO-OP-004,
" Dewatering Procedure for the 24-Inch Diameter Pressure Demineralizer Vessel Containing Ion Exchange Resins" used on at least once occasion during
- 1985, had not been reviewed since June 15, 1983, an interval of more than two years.
Corrective Actions Taken A review of procedure FO-OP-004 was performed and documented.
Actions Taken to Prevent Recurrence A
log to track the reviews of Radwaste procedures has been generated to ensure the two-year review requirement is met.
Date of Full Compliance Full compliance has been achieved at this time.
i 1
A a
R ply to Notica of Violation
.Thspection 86-05 Letter datcd April 21, 1986 Page 5 VIOLATION D (Severity Level V; Supplement V)
Description of Violation (86-05-04) 10 CFR 71.12(a) permits a
general license to bG issued to any g
licensee of the commission to transport, or deliver to a carrier for transport, licensed material in a package for which a certaficate of compliance has been issued by the NRC.
10 CFR 71 12(c)(1) states, in
- part, that this general license a.oplies only to a Jicensee who has a p
copy of the certificate of compliance and has the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging and to the actions to be taken prior to shipment.
Contrary to the above, on April 23 1985, the licecsce delivered to a carrier for transport 29,14 Curies of licensed material in a packa.gu, Model No.
CNS 6-80-2, Certificete of Compliance (O of C) No. 9141, and although the licensee had a reduced copy of a drawir.g, it cou,1d not be verified as the referenced draWir.g because the drraing identification number was not legibJc.
Admission or Denial of Violation Duquesne Light Company denies Violation 86-05-04.
J1 Discussion In order to determine if the reduced copy of the drawing in guertion was the referenced drawing for package Model No. CNS C-80-2, C cf C No.
- 9111, another copy of the refe.renced draaing (C.'.10-D-0028 Rev.
A) was obtained.
Upon receipt, we tier.e able to veri.f'1 that the copy of the drawing kept by the RadWaste Coordirsatcr at Beaver Valley Unit 1
was indeed the correct drawing.
This f at:t was agairt varified by Quality Assurance personnel as part of a
recent GA audit (BV-1-86-08).
Since a
copy of the referenced drawing
- war, in f.act,
in cur possession, there was no violati6n of the requirements of 10 CFR 71.12(c)(1).
Therefore, we respectfully request that thit v.iola*.lon i
be withdrawn.
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