ML20195D846
| ML20195D846 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/27/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8811070154 | |
| Download: ML20195D846 (2) | |
See also: IR 05000382/1988020
Text
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.
OCT 271988
In Reply Refer To:
Docket:
50-382/88-20
Louisiana Power & Light Company
ATTN:
J. G. Dewease, Senior Vice President
Nuclear Operations
317 Baronne Street
New Orleans, Louisiana 70160
Gentlemen:
Thank yp[for your letter of October 10, 1988, in response to our letter
dated August 24, 1988 (Unresolved Item 382/8820-02), and telephone request of
September 9,1988, for detailed information on your actions to resolve several
State of Nevada identified violations of the U.S. Department of Transportation
(00T) regulations involving radioactive waste shipments from your facility.
These violations involved several of your radioactive waste shipments to the
Beatty, Nevada burial site during the period of May 31, 1988, through June 6,
1988. Your corrective actions appear to be sufficient to prevent future
recurrence of the violations. We find your response fully responsive to our
request and we have no further questions at this time. We will examine
implementation of your corrective actions to these 00T violations during a
future inspection. We will also determine at that time whether further
enforcement action is warranted.
Sincerely.
Original Signed By,
L J. Callan
L. J. Callan, Director
i
Division of Reactor Projects
cc:
Louisiana Power & Light Company
ATTN:
G. E. Wuller, Onsite
Licensing Coordinator
P.O. Box B
K111ona, Louisiana 70066
Louisiana Power & Light L.epany
ATIN:
N. S. Carns, Plant Manager
P.O. Box D
Killona, Louisiana 70066
Middle South Services
ATTN: Mr. R. T. Lally
P.O. Box 61000
New Orleans, Louisiana 7 161
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Lout siana Power & Light Company
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Louisiana Power & Light Company
ATTN:
R. F. Burski, Acting Manager
Nuclear Safety and Regulatory
Affairs
317 Baronne Street
P.O. Box 60340
New Orleans, Louisiana 70160
Louis',ana Radiation Control Program Director
bec to DMB (IE06)
bec distrib. by RIV:
RRI
k. D. Martin, RA
Section Chief (DRP/A)
RPB-DRSS
MIS System
Project Engineer, DRP/A
RSTS Operator
RIV File
D. Wigginton, NRR Project Manager
Lisa Shea, RM/ALF
Inspector
B. Murray
R. Baer
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P O W E A & t. I G H T
NEW OnLEANS. LOUISI AN A 70160 *
(504) 595-3100
N N S sIET*
Y
October 10, 1988
A4.05
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C.
20555
SUBJECT: Waterford Steam Electric Station - Unit Number 3
Docket Number 50-382
NRC Inspection Report 88-20
Gentlemen:
The subject Inspection Report identified unresolved item 8820-02 regarding
transportation-related violations issued by the State of Nevada against low
level radioactive waste shipments from Waterford 3 to the Beatty, Nevada
disposal site. Messrs. D. Chaney and R. Baer, NRC Region IV, requested a
letter summarizing the status of these violations durfrg a conference call
on September 9, 1988. This letter responds to their Yaquest.
Low level radioactive waste shipment numbers 88-1008 and 88-1009 arrived at
the disposal site o May 31, 1988 and June 3, 1988, respectively; 88-1010
and 88-1011 both arrived on June 6, 1988.
These shipments all arrived
within a one week period and are the shipments for which violations were
issued.
The violations can be summarized as follows:
1.
Manifests accompanying shipment numbers 88-1008, 1009, and 1011
each had an illegible copy attached;
2.
One of the placards on the front of the vehicle transporting
shipment number 88-1008 was improperly displayed; and
3.
Shipment number 88-1010 appeared to have shifted slightly during
transport and a small hole was found on the front of one of the
packages in the shipment.
Another violation had been issued against shipment number 88-1010, citing
discrepancies between package dose rates indicated on the manifest and
those measured at the disposal site. This violation was rescinded,
however, after Louisiana Power & Light Company (LP&L) contacted the
disposal site Radiation Safety Officer and demonstrated that the violation
could not have been issued against LP&L's shipment.
7
$ ;al M C
"AN EQUAL OPPORTUNITY EMPLOYER"
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,
Page 2
October 10, 1988
,
LP&L instituted corrective actions, including procedural revisions and
j
review of the violattens, regulatory requirements and procedural revisions
with personnel involved with radioactive waste shipeer.ts in response to
t
these violations. These actions were detailed in letters to the State of
Nevada dated July 5, 1988, July 25, 1988, and August 4, 1988. The State of
Nevada acknowledged LP&L's corrective actions in letters dated July 12,
!
1988, August 1, 1988, and August 12, 1988; and provided clarification that
l
LP&L could resume shipments to Beatty in a letter dated September 19, 1988.
'
a
LP&L feels that it has appropriately addressed these violations, and based
on correspondence from the State of Nevada, considers these violations
closed.
Messrs. Chaney and Baer indicated during the aforementioned conference call
that unresolved item 8820-02 could be closed based on documentation of
resolution by the State of Nevada. Copies of all correspoadence referenced
j
in this letter, plus the letter rescinding the dose rate violation, and the
!
letters citing the violations are attached for your review.
These
i
,
i
attachments comprise a complete package of all correspondence related to
,
the violations and document the fact that this issue has been resolved with
l
!
the State of Nevada, pending inspections of future shipments to Beatty to
verify that the corrective actions have been effective. LP&L therefore
j
requests that unresolved item 8820-02 be closed.
l
,
l
4
Specifies of the violations and corrective actions have not been reiterated
!
!
in this letter as the information is fairly detailed and clearly presented
!
in the attached correspondence.
Should you wish to discuss this matter
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further or require additional information, please contact Chadi D. Croome
i
at (504) 595-2846,
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Yo rs very truly,
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R.
Burski
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Nuclear Safety & Regulatory Affairs
RFBtCDGtssf
-
Attachments
cet
E.L. Blake, W.H. Stevenson, J.A. Calvo
D.L. Wigginton, 4.D. Martin.
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NRC Resident Inspector's Office (W3)
- i
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List of At tached correspondence
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State of Nevada to LP5L - 8 letters dated:
June 7, 1988
June 30, 1988 (3 letters)
July 12, 1988
August 1, 1988
August 12, 1988
September 19, 1988
LP6L to State of Nevada - 3 letters dated:
July 5, 1988
July 25, 1988
August 4,
1988
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DEPARTMENT OF HUMAN RESOURCES
HE ALTH Dl%3510N
m.o.l. sic.i Hestih 5.cii.n
505 East King Street. Room 203
Carson City. Nevada 89710
(702) 885 5394
June 7,
1988
J.M. Cain
Louisiana Power and Light Company
317 Baronne Street
New Orleans, LA
70160
Ce.ir Mr. Cain:
.
This letter is in reference to Louisiana Power and Light Company
LLW shipment no. 88-1008 which arrived at the Beatty, NV disposal
site on May 31, 1988 under Nevada Site User Permit No. Q446.
Inspection findings revealed the follcwing violations:
1.
001-Q446-4-1
U.S.
Department
of
Transportation
regulation
49
CFR
172.516(c)(4) requires each placard to be located away f rom any
marking, such as advertising, that could substantially reduce its
effectiveness, and in any case, at least 3 inches (76.0 mm.) away
from such markings.
Contrary to this requirement, the placard located on the front of
the transport vehicle was located within three (3) inches of a
license plate holder which was displaying four license plates.
The top of the placard was also wrapped over the top of the
vehicle bumper which should be prevented on future shipments.
The entire placard must remain completely visible.
2. 001-Q446-4-2
49.
CFR
172.201(a)(2)
states
that
the
required
shipping
description on a shipping paper and all copies thereof use for
transportation purposes, must be legible and printed (manually or
mechanically ) in English.
M ! 41988
_
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.
Contrary to tnis requirement, the carrier copy of the shicp;ng
manifest furnished with the shipment had several portions which
were not clearly legible.
The violation appears to be a result
'
of
an
improper
printer
font
or
inadequate
pressure
on
the
printer.
You are required to advise this office in writing within 20 days
of your receipt of this letter to indicate the actions that will
be taxen to correct these violations, when the corrective actions
will be implemented and the methods that will be taken to prevent
recurrence of the violations.
Sincerely,
( 'l k,M g0n
Stanihy)
R.
Marshall,
Supervisor
Radiological
Health
Section
Bureau of Regulatory Health Services
Enclosure
11wsiplevioltr
,
,
cc:
Bill Spell, State of Louisiana
virgil Autry, State of
.
Earl Ingersoll, State of Washington
Jr,4. / r' :- ~
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Jack
Hornor, Region V, NRC
Bert Gray, Nevada Health Division
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IMPROPERLY DISPLAYED PIACARD
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DEPARTMENT OF HUMAN RESOURCES
HE ALTH D1%I510%
Radeelegnal Health lettien
505 East King Street. Room 203
Carson City. Nesada 89710
(702) 885 5394
June 30, 1988
i
J. M. Cain
Louisiana Pcwer and Light Company
317 Baronne Street
New Orleans, LA
'70160
RE: 003-Q446-2-1
003-Q446-3-1
003-Q446-3-2
-
,
Dear Mr. Cain:
This letter is in reference to the Louisiana Power and Light
company LLW shipment number 88-1010 which arrived at the Beatty
site on June 6,
1988.
The shipment was made under Nevada Site
User Permit No.
Q446
issued
to
Power
and Light
Company, Waterford 3 SES.
Inspection findings revealed the following violations:
1.
003-Q446-2-1
U.S.
Department
of
Transportation
regulation
49
CFR
173.425(b)(1) requires materials to be packaged in strong, tight
packages so that there will be no leakage or radioactive material
under conditions normally incident to transportation.
Contrary to this requirement, package number 88-0111 was found to
have
a
hole
in
the
front
of
the
package.
The
hole
was
approximately 1/4 inch in diameter and was located 20 inches from
the left side and 20 inches from the bottom of the package.
No
loss of container contents was found as a result of the hole in
the package.
l
2.
003-Q446-3-1
JUL
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49 CTR 173.415(b)(6) requires the shipment t0 he braced s
as ::
prevent shi: ting of lading under conditions ncrmally inciden: ::
transportation.
-
49 CFR 173.448(a) requires each shipment of radioactive material
to
to
secured
in
order
to
prevent
shifting
during
normal
transpcrtation conditions.
Contrary to tnese requirements, tne containers were found to have
shifted to tne front of the trailer as a result of the woeden
wedges ceing released from between the containers curing transit.
The release of the wedges created approximately 6 inches of space
between the rear floor bracing materials and the rear packages.
3.
003-Q446-3-2
Nevada Administrative code 459.823(2)
requires
the manifest te
contain a statement which is as complete as is practicable and
>
includes a physical description of the waste,
its volume, the
identity
and
quantity
of
radionuclides,
the
total
radioactivity and the principal enemical form.
Contrary to this requirement, three packages
were
found
to
.
.
have external radiation levels
significantly different than the
radiation levels indicated on the shipping manifest.
The three
-
!
packages,
the
indicated levels and measured radiation levels
are as follows:
package No.
Indicated rad. level
Measured rad, level
0111
800.0
mR/hr
550.0 mR/hr
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'
0049
60.0 mR/hr
100.0 mR/hr
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0047
80.0
mR/hr
110.0 mR/hr
f
Mr.
Larry
Simon
from
your
company
was
present
during
confirmation of the findings above.
You
are
required
to
advise
this
office
in
writing within
>
20 days of your receipt of this letter of the actions that will
be
taken
to correct
the violations, when the corrective
actions will
be implemented and
the methods that will be used
to prevent recurrence of the violations.
Upon receipt of
the correctiva actions,
we will review the
response and advise you concerning resuming shipments to the
.
Beatty site.
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.
- _ - . _ - - - - - - - _ . - - - . _ _ -
.
_ _ _ _ _
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.
If you have any questions, please feel free to contact me.
.,.
Sincerely,
h
Stanigly R. Marshall. Supervisor
~
Radiological Health Section
Bureau of Regulatory Health Services
lw2\\lplcitr
cc:
Bert Gray, Nevada Health Division
Virgil Autry, State of South Carolina
Earl Ingersoll, State of Washington
Jack Horner, Region V, NRC
Bill Spell, State of Louisiana
Novelle Tucker, U.S. DOT
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STATE OF NE% AD4
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JERRY ORitPt%f2OG
JOSEPH Q J4Rtl% MD
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DEPARTMENT OF HUMAN RESOURCES
HE Alf H DIVISION
Radlelegkal Health Se<tten
505 Esot King Street, Room 203
Carson City, Nevada 89710
(702) 885 5394
June 30, 1988
J. M. Cain
Louisiana Power and Light Company
317 Baronne Street
New Orleans, LA
70160
RE:
002-0446-4-2
.
Dear Mr. Caint
-
This letter is in reference to the Louisiana Power and Light
Company LLW shipment number 88-1009 which arrived at the Beatty
site on June
3,
1988. The shipment had been made under Nevada
Site User Permit No.
Q446 issued to Louisiana Power and Light
Company, Waterford 3 SES.
Inspection
findings revealed the following violation:
1.
002-0446-4-2
U.S.
Department
of
Transportation
regulation
49
CFR
172.201(a)(2)
requires the shipping description on a shipping
paper and all copies thereof used for transportation purposes, to
be legible and printed (nanually or mechanically) in English.
Cont rary to this requirement, the carrier copy of the shipping
man;fest f
hed with the Louisiana Power and Light Company
shipment n
88-1009 was not legible.
This appears to have
been caused
the printing style of the manifest printer.
You are required to advise this office within 20 days of your
receipt of this letter of the actions that will be taken to
correct
the
violation,
when
the
corrective
actions
will
be
implemented
and
the
methods
to
prevent
recurrence
of
the
violation.
,
JUL
619Q
. _ _ _ _ _
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..
,
.
,
If you have any questions,
please feel
free
to contact me.
-
Sincerely,
Sta Wey R. Marshall, Supervisor
Radiological Health Section
Bureau of Regulatory Health Services
lw2\\lplevioltr
cc:
Bert Gray, Nevada Health Division
Jack Hornor, Region V, NRC
Virgil Autry, State of South Carolina
Earl Ingersoll,
State of Washington
Bill spell, State of Louisiana
Novelle, Tucker, U.S. DOT
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JERRY GRitPt%TIOG
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DEPARTMENT OF HUMAN RESOURCES
HEALTH 04%I510N
Roseleg6 sal Health Section
505 East King Street. Room 203
Carson City, Nevada 89710
(702) 885 5394
June 30, 1988
J. M. Cain
Louisiana Power and Light Compaty
317 Baronne Street
New Orleans, LA ,70160
'
RE:
004-Q446-4-3
Dear Mr. Cain:
i
,
This letter is in reference to the Louisiana Power and Light
company LLW shipment number 88-1011 which arrive at the Beatty
site on June 6,
1988.
The shipment had been made under Nevada
Site User Permit No.
Q446 issued to Louisiana Power and Light
Company, Waterford 3 SES.
!
Inspection findings revealed the following violation:
(
1.
U.S.
Department
of
Transportation
regulation
49
CFR
172.201(a)(2) requires the shipping description on a shipping
paper and all copies thereof used for transportation purposes, to
be legible and printed (manually or mechanically) in English.
Contrary to this :;equirement , the carrier copy of the manifest
could not be read.
This appears to have been caused by the
printing style of the manifest printer,
you are required to advise this office within 20 days of your
i
receipt of this letter of the actions that will be taken to
,
correct
the
violation,
when
the
corrective
actions
will
be
implemented
and
the
methods
to
prevent
recurrence
of
the
violation.
>in erely,
i
'
'
L.
_ _
a
y R. Marshall, Supervisor
Radiological Health Section
Bureau of Regulatory Health Services
JUL
6 1988
..
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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cc:
Bart Gray, Nevada Health Division
,
Jack Hornor, Region V. NRC
Virgil Autry, State of South Carolina
Earl Ingersoll,
State of Washington
l
Bill Spell, State of Louisiana
'
Novelle Tucker, U.S. DOT
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DEPARTMENT OF HUMAN RESOURCES
HE4LTH Dl%IblO%
i
n,ai.i. ...i H..iin se.....
SC Ea .: King Street. Room 203
arson City. Nnada 89710
1702) 885 5394
July 12, 1988
>
R.
F. Burski, Manager
Nuclear Safety and Regulatory Affairs
Louisiana Power and Light C mpany
,
P.O. Box 60340
Mall Unit N-17
New Orleans, LA '70160
,
,
Cear Mr. Burski:
Your letter dated July
5,
1988 is acknowledged.
The letter
describes
the
actions
that
have
been
taken
to
correct
the
violations documented during our recent inspection of Louisiana
Power and Lignt Ccmpany LLW shipment number 88-1008.
.
The
corrective
actions
will
be
reviewed
during
future
inspections.
You are requested to respond to the violation letters concerning
shipment numbers 88-1009, 88-1010 and 88-1011 prior to resuming
shipments to the Beatty site.
If you have any questions,
please feel free to contact this
office.
!
' h at ely,
'
r%
'3 t d y R. Marshall, Supervisor
'
Racio 1gical Health Section
Bureau of megulatory Lalth Services
cc:
Bert Gray, Nevada Health Division
Bill Spell, state of Louisiana
l
Virgil Autry, State of South Carolina
t
Earl Ingersoll,
State of Washington
Jack Hornor, Region V, NRC
Novelle Tucker, U.S. Dept. of Transportation
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Jimmy GaltPEMISOC
Mee eb Cl;tse.
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DEPARTMENT OF HUMAN RESOURCES
HLALfH O(VilWM
Red 8. lee $aal Meettt lectlen
505 East Klag Street. Roofa 203
.
Careen City. Nevede s9710
August 1, 1998
0o2) ses.5394
R. F. Burski, Manager
Nuclear Safety and Regulatory Affairs
Louisiana Power & Light
317 Baronne Street
New Crleans, LA
70160
RE:
002-0446'-4-2
004-Q446-4-3
Dear Mr. Burski:
Your letter dated July 25, 1988 is acknowledged.
The letter
describes the actions that have been or will be taken to correct
the
violations documented during
recent
inspections
of
shipments from Louisiant Power & Light.
The corrective actions will be reviewed during future inspections
to deternine their effectiveness.
We are still awaiting a
response to our letter dated June 30, 1988 concerning your LLW
shipment number 88-1010.
Upon' receipt of the response, we will consider reinstatement of
permission to ship to the Beatty site.
If you have any questions, please feel free to contact me.
incerely,
h
- a
y R. Marshall, Supervisor
Radiological Health Section
Bureau cf Regulatory Health Services
lw2\\lpl81txt
cct
Bert Gray, Nevada Health Division
.
Jack Hornor, Region V. NRC
'
Virgil Autry, state of South Carolina
Earl Ingersoll,
state of Washington
Bill Spell, State of Louisiana
Novella Tucker, U.S. Dept. of Transportation
..
SEP 15 '88 14: 16
PAGE.002
_ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _
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STATE OF st%ADA
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DEPARTMENT OF HUMAN RESOURCES
HEALTH OtVill0N
neces veel He.iin secie.a
505 East King Street. Room 203
Carson City. Nevada 89710
(702) 885 5394
August 12, 1988
R.
F.
Burski, Manager
Nuclear Safety & Regulatory Affairs
Louisiana Power & Light
317 Baronne Street
New Oricans, LA
70160
RE: 003-Q446-2-1, 003-Q446-3-1
.
Cear Mr. Burski
Your letter dated August
4,
1988 is acknowledged.
The letter
described actions that will be taken to correct the violations
documented during the recent inspection of LLW shipment no.
88-
1010 from Louisiana Power & Light.
The corrective actions were
in response to violation numbers 003-Q446-2-1 and 003-Q446-3-1
cited in our letter dated June 30, 1988.
The corrective actions will be reviewed during future inspections
to determine their effectiveness.
If you have any questions,
please
feel
free
to contact me.
Sincerely,
4%nOot0
A
V I
-
x
ha
Ly R.' Marshall, Supervisor
Radiological Health Section
Bureau of Regulatory Health Services
lw2\\lpivioltr
cc:
Bert Gray, Nevada Health Division
Earl Ingersoll, State of Washington
Virgil Autry, State of South Carolina
Novelle Tucker, U.S. Dept. of Transportation
Bill Spell, State of Louisiana
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STATE OF NEVACA
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DEPARTMENT OF HUMAN RESOURCES
MEALTH DM83084
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(702) 845 5394
September 19, 1988
Chadi Groome
Louisiana Power and Light company
P.O. Box 60340
i
Mail Unit N-17
New Orleans, LA
70160
Dear Ms. Groomel
This letter is in response to the
ree. test from your management
concerning LLW shipments to the Beatty, NV site under Nevada Site User
'
Permit No.
Q446 issued to Louisiana Power and Light Company.
l
Your lettern dated July 5,
1988, July 25, 1988 and August
4,
1988
to this office described the corrective actions
for
recent LLW
shipreents to the Beatty site.
Cur letters dated July 12, 1988, Augu:r
!
L2 and August 13,1988 advised that the corrective actions would be
reviewed during future inspections of shippents frore Louisiana Power
i
!
and Light company.
I regret that our review of the corrective actions
and acknowledgments in writing were not interpreted by your manage: tent
to include permission to resume shipments to the Beatty site.
You are advised that Louisiana Power and Light company is perraitted to
l
resume LLW shipments to the neatty site.
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SEP 20 '88 12:01
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If you have any further questions, please feel free to contact re.
Sincerely,
stan
R. P,4:shall, Supervisor
Radiological Health section
Bureau of Regulatory Health Services
lw2\\1pigrmeltr
cca
Bert Gray, Nevada Health Division
Virgil Autry, State of South Carolina
Earl Ingersoll, state of Washington
Bill spell, state of Louisiana
.
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PAGE.002
SEP 28 '88 12:01
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l OUISl AN A / m eaacssistam .
o ec,seu:
.
P OW E A & LiG H T
NEA CALEANS LewS AN A 70160
($041 $95 P;c
.
Y ii \\ Us$~s
l
July 5, 1988
A4.06
Mr. Stanley R. Marshall
Department of Human Resources
Health Division
Radiological Health Section
505 East King Street, Room 203
Carson City, Nevada 98710
SUBJECT:
Vaterford Steam Electric Station - Unit Number 3
Nevada Radioactive Waste Disposal Site User's Permit
.
Number Q446
Low Level Waste Shipment Number 88-1008
REITRENCE:
Department of Human Resources Letter from
Stanley R. Marshall to J.M. Cain dated June 7, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of the referenced
letter indicating that two transportation-related violations were issued
against LP&L's low level waste shipment number 88-1008. This shipment
arrived at the Beatty, Nevada disposal site on May 31, 1988. The refer-
enced letter was received on June 14, 1988, and requires a response
within 20 days of receipt.
As is discussed in detail below, LP&L bas
reviewed the violations and has initiated corrective actions to prevent
their recurrence.
Violation number 001-Q446-4-1 indicates that the placard on the front of
the transport vehicle was placed within three (3) inches of the license
plate b' older, ano therefore not in conformance with the requirements of
49CFR172.516(c)(4).
Photographic documentation was included in the
referenced letter to substantiate this finding.
Violation number 001-Q446-4-2 indicates that several portions of the
carrier copy of the shippin8 manifest were not clearly legible, and
"AN ROUAL OPPORTUNITY EMPLOYER"
Pago '
'
July 3,
i900
.
.
therefore violated the requirements of 49CTR172.201(a)(2).
This regu-
lation specifies that:
The required shipping description on a shipping paper
and all copies thereof used for transportation purposes,
must be legible and printed (manually or mechanically)
in English.
LP&L was aware prior to the shipment leaving Waterford 3 that the carrier
copy of the sanifest was not entirely legible, and tcok what it considers
appropriate compensatory action.
The manifest required by the disposal
site is a five part carbon form, the last copy of which generally does
not print clearly.
As LPEL has been doing for quite some time, the first
page of the manifest was photocopied and designated as the carrier copy
in lieu of the last page of the five part manifest.
In fact, both the
State of Nevada Site Inspector and disposal site personnel suggested
substituting photocopies for illegible carbon copies when LP&L questioned
.
them about resolving the legibility concern.
To avoid future confusion
regarding which copies are used f ar transportation purposes, any copies
which may be deemed illegible and are replaced by photocopies will be
removed from the manifest.
Radwaste Department Technical Procedure number RW-2-501, "Radioactive
Waste Shipments" provides instructions regarding Department of Transpor-
tation Nuclear Regulatory Commission and disposal site requirements for
radioactive waste shipments.
The procedure requires completion of
checklists to insure that the proper paperwork and notifications have
been completed, and that the shipeents and transport vehicles meet the
applicable regulations prior to leaving Waterford 3.
In light of these
violations, the procedure has been reviewed, and is being revised to be
more specific with regard to both placarding and shipping paper legibil-
ity requirements.
Approval of the chaeges is expected within the next
two weeks, but in any case will be received prior to the next radioactive
waste shipment.
In addition, these vialationa and applicable regulatory
requirements have been reviewed with personnel involved with radioactive
waste shipments.
To insure timely responses, please address future correspondence to me.
My address ist
P.O. Box 60340
Mail Unit N-17
New Orleans, Louisiana 70160
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _
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W3PS8 1631
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July 5,
19e8
.
St.ould you require additional information regarding these violations,
please contact Ms. Chadi D. Grocee at (504)$95-2846.
Very truly yours,
gl,g...i
R.F. Burski
Nuclear Safety & Regulatory Af f airs
Manager
RTB/C3Gdsy
cc:
J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. Lalont'e,
L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell,
V. Autry, E. Ingersoll, J. Hornor, B. Gray, Waterford 3 Records Center,
Administrative Support (1), Licensing Library
_. . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
. _ _ _ _ _ _ _ .
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f.O U181 AN A / m eiacsse starir
. o ecm :
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POW E A & LIGH T
NEW CALEaNS Low $iaNA 701W .
6C4> $95 000
'$*U1s 5.%'O
July 25, 1988
A4.06
Mr. Stanley R. Marshall
Department of Human Resources
Health Division
Radiological Health Section
505 East King Street, Room 203
Carson City, Nevada 98710
SUBJECT:
Waterford Steam Electric Station - Unit Number 3
Nevada Radioactive Waste Disposal Site User's Permit
.
Number Q446
Low Level Vaste Shipment Numbers 88-1009 and 88-1011
RITERENCES:
(1) State of Nevada Department of Human Resources Letter from
Stanley R. Marshall to J.M. Cain dated June 30, 1988
Regarding Louisiana Power & Light Company Low Level Vaste
Shipment Number 88-1009
(2) State of Nevada Department of Human Resources Letter from
Stanley R. Marshall to J.M. Cain dated June 30, 1988
Regarding Louisiana Power & Light Company Low Level Vaste
Shipment Number 58-1011
(3) Louisiana Power & Light company Letter W3P88-1631 from
R.F. Burski to Stanley R. Marshall dated July 5, 1988
(4) State of Nevada Department of Human Resources Letter f rom
Stanley R. Marshall to R.F. Burski dated July 12, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of references 1 and 2
which describe transportation related violations issued against LP&L's low
level waste shipment numbers 88-1009 and 88-1011 which arrived at the Beatty,
Nevada disposal site on June 3, 1988 and June 6, 1988, respectively.
As both
violations are the same, they are being addressed together in this letter.
Also, we would like to note that these violations are the same as violation
number 001-446-4-2
for which corrective action has been initiated, as
described in reference 3 and acknowledged in reference 4.
.
"AN EDUAL OPPORTUNITY EMPLOYER"
0000 *
b3PS$.te23
,.
.,
July 25, 1988
.
.
These two violations indicate that several portions of the carrier copy of
the shipping manifests were not clearly legible, and therefore violated the
requirements of 49CTR172.201(a)(2).
This regulation specifies that:
The required shipping description on a shipping paper and all
copies thereof used for trans e:rta tion purposes, must be
legible and printed (sanually
mechanically) in English.
LP&L was aware prior to the shipments leaving Wsterford 3 that the carrier
copies of the manifests were not entirely legible, and took what it considers
appropriate compensatory action.
The manifest 'aquired Ay the dispossi site
is a five part carbon form, the last copy of which p,onerally does not print
clearly.
As LP&L has been doing for quite some time, the first page of the
manifest was photocopied and designated as the carrici copy in lieu of the
last page of the five part manifest.
In fact, both the State of Nevada Site
Inspector and disposal site personnel suggested substituting photocopies for
illegible carbon copies when LP&L questioned thee about resolving the legi-
bility concern.
To avoid future confusion regarding which copies are used
for transportation purposes, any copies which may be deemed illegible and are
replaced by photocopies will be removed from the manifest.
,
Radwaste Department Technical Procedure number RW-2-501, "Radioactive Waste
Shipments" provides instructions regarding Department of Transportation,
Nuclear Regulatory Commission and disposal site requirements for radioactive
waste shipments.
The procedure requires completion of checklists to insure
that the proper paperwork and notifications have been completed, and that the
shipments and transport vehicles meet the applicable regulations prior to
'
leaving Waterford 3.
In light of these violations, the procedure has been
revised to be more specific with regard to shipping paper legibility require-
raent s .
In addition, these violations and applicable regulatory requirements
have been reviewed with personnel involved with radioactive vaste shipcents.
Should you require additional information regarding these violations, please
contact Ms. Chadi D. Grocee at (504)595-2846.
l
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Very truly yours.
l
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R.F. Burski
Nuclear Safety & Regulatory Af f airs
Manager
RTBfW8/Isy
!
cc
J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. LaBonte.
L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.M. Spell,
V. Autry, E. Ingersoll, J. Hornor, B. Gray, N. Tucker, Waterford 3
Records Center, Administrative Support (1), Licensing Library
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LOUl81ANA / meAacss
Starit . e o sex ecuo
POWEA & LiG H T
NEW C ALE ANS LOWS 1N A 70160 * (SC0 595 3t00
5'5511 dIsNO
August 4,
1988
A4.06
Mr. Stanley R. Marshall
Department of Human Resources
Health Division
Radiological Health Section
505 East Kinz Street, Room 203
Carson City, Nevata 98710
SUBJECT
Waterford Steam Electric Station - Unit Number 3
Nevada Eadioactive Waste Disposal Sito User's Porait
Number Q446
'
Low Level Waste Shipment Number 84-1010
RITERENCES:
(1) State of Nevada Department of Human Resources Letter from
Stanley R. Marshall to J.M. Cain dated June 30, 1988
Regarding Louisiana Power & Light Company Low Level Vaste
Shipment Number 88 1010
(2) State of Nevada Department of Human Resources Letter from
Stanley R. Marshall to Chadt Groome dated July 18, 1988
Dear Mr. Marshall
Loutstana Po* er & Light Company (LP&L) is in receipt of the references letters
discussing transportation-related violations issued against LP&L's low level
waste shipment number 88-1010. This shipment arrived at the Beatty, Nevada
disposal site on June 6, 1988. As is discussed in detail below LP&L has
reviewed the violations and has initiated corrective actions to prevent their
recurrence.
Violation number 003-446 2-1 indicates that contrary to 49CFR173.425(b)(1),
which requires that "Materials must be packaged in strong, tight packages
to that there will be no leakage of radioactive material under conditions
normally incident to transportation", package number 88 0111 was found to
have a hole approximately 4 inch in diameter on the front of the package.
The violation continues that "No loss of container contents was found as
a result of the hole in the package." While LPkL is not sintaising the seri-
cuaness of a breach of integrity in a shipping package, it is important to
note that this small hole did not result in leakage of radioactive materia *.,
and therefore the package sat the intent of the cited regulation.
"AN ROUAL OPPCMtTUNffY EMPLOYER"
_.
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Page 2
W3P88 1630
.
As a result of this violation, LP&L has taken several steps to insure the
integrity of its shipping packages.
Packages already on site were reinspected.
Radwaste Department Technical Procedure numbers RW-2-501, "Radioactive Waste
Shipments", and RW 2 300, "Receipt. Storage and Leading of Shipping Contain-
ers", have been revised to clarify acceptance criteria and focus both receipt
and final (prior to shipment) inspections on box integrity.
Furthermore,
while not a regulatory requirement for this type of container, procurement
specifications have been upgraded to Quality Class II which imposes more
stringent controls on both the vendor and LP&L.
Violation number 003-Q446-3 1 indicates that the subject shipment did not
meet the requirements of 49CTR173.425(b)(6) snd 49CTR173.448(a) in that "the
containers were found to have shifted to the front of the trailer as a result
of the wooden wedges being released from between the containers during transit.
The release of the wedges created approximately 6 inches of space between
the rear floor bracing saterials and the rear packages." The cited regula.
tions specify, respectively:
,
Shipment must be braced so as to prevent shifting of lading
under conditions normally incident to transportation.
,
and
Each shipment of radioactive materials shall be secured
in order to prevent shifting during normal transportation
conditions.
In response to this violation. LP&L has thoroughly reviewed its loading
practices and discussed the incident with personnel involved with radioactive
,
vaste shipments.
gxtreme care was taken in preparing this shipment for
transportation. The methods employed to secure the boxes should have been
adequate to prevent the cargo from shifting to any appreciable degree, and
an explanation of the loading procedures is in order at this time.
The ship-
ment consisted of ten boxes. The boxes were centered in the trailer, one
behind the other, with the first box placed flush against the front wall
of the trailer, and each subsequent bru abutting the box in front of it.
(secause the boxes bow slightly when full, the tops of the boxes could not
be placed se,uarely against each other.) Yvo by fours were nailed to the
floor of the trailer around each box to keep the boxes in place during transit.
A restraining device (a metal bar and ratchet mechanism) secured to the sides
of the trailer (approximately three fourths up froc the bottom of the box)
was installed behind the fourth box to further inhibit movement and another
was installed behind the last box to keep the cargo from moving backward
toward the trailer doors.
In addition, cargo straps were strung froe side
to side in the t!ailer behind every other box.
gecauge the boxes were slightly
bowed and the tops could not abut, wooden wedges were driven between the
boxes to further maintain the existing spacing and provide shock absorption.
_
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Page 3
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Apparently some of these wedges vibrated free and gav
ae aoraarance that
the load may have shifted. As the wedges were not ne
- n secure the
shipment, they will not be used for future shipments.
As reference 2 rescinded violation number 003-Q446-3-2, the
ed violation
cited in reference 1, this violation does not require a r*
.s e .
However,
LP&L wishes to point out that its efforts in investigating the violation
identified the differences between the information presented in the viola-
tiur, and LP&L's documdntation for the subject shipment. These differences
were confirmed by the U.S. Ecology Site Radiation Safety Of ficer during a
telephone call with LP&L personnel. The violation cites discrepancies between
radiation levels measured at the disposal site and those indicated on the
shipping manifest for three boxes. Two box numbers, 047 and 049, do nct
match any box numbers on LP&L's manifest.
Tite third box number, 0111, was
indicated on the manifeat. However, the violation specifies that the
manifest indicated a radiation level of 800 mR/hr for this box, while the
'
highest radiation level of any. box in she subject se peent was 500 mR/hr
,
contact. .As the documentation clearly indicates, these radiation level dis-
crepancies could not have been cited against the subject shipment, and LP&L
a
appreciates your letter rescinding :his violation.
Should you require additional information regarding these violations, please
contact Ms. Chadi D. Groome at (504) 595-2846.
Yours very truly,
. .
R.F. Burski
Manager
Nuclear Safety & Regulatory Affairs
RFB/CDCIp1m
cci
J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. La3onte,
J. Ridgel, L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson,
W.H. Spell, V. Autry, E. Ingersoll, J. Hornor, B. Gray, N. Tucker,
Waterford 3 Records Center, Administrative Support. Licensing Library
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4
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DOCUNINTATION OF
TELEPHONE COMMUNICATIONS
.
7 ATE:
September 9,
1988
TIME:
1000
A.M.
ggg,
B.C. Morrison, C.D. Groome
y
PARTY CALLINC:
J.A. Ridgel, L.R.
Simon
//
LP&L
(Name)
p#
(Company)
H.D. Chaney
PARTY ANSWIRING:
0.E. Baer
NRC. Region IV
(Name)
(Company)
SUPJECT:
IR 88-20
FILE:
A7.09
._
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.SUMHARY:
(INCLUDING DECISIONS AND/OR COMMENTS)
.Chadi discussed the Nevada violations and indicated that all items had been taken
-
care of.
The NRC wants a summary of the problems and resolutions in a formal letter.
Chaney addressed the training response required by IR 88-20.
He wants us to forms. ty
1
document our commitment to IFB 79-19 items 5 and 6 and how we are going to keep
the Radwaste Training up-to-date.
............. ... ....-------------------------------------------------------------------
ACTION RIQUIRED:
Chadi vill submit a letter on Nevada questions.
Barbara and Marty Langen will
i
prepare response to training question.
DISTRIBUTION:
Records Center Administrative Support, Licensing Library, Site Licensing
Support File
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UNITED STATES
n
[
e\\
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NUCLEAR REGULATORY ^
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CEGloN IV
,
til AYAN PLAZA DRIVE. bLlTC '900
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ARLINGTON, TEXA5 *, ;11
- q g gy
- ECEriED fr'
,
r_ ADMINISTRATIVE SUPPORT
In Reply Refer To:
Docket:
50-382/88-20
ggp 3
ygg
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Louisiana Power & Light Company
ATTN:
J. G. Dewease, Senior Vice President
.
Nuclear Operations
317 Baronne Street
New Orleans, Louisiana 70160
i
Gentlemen:
This refers to the inspection conducted by Mr. H. D. Chaney of this office
during the period July 10-15, 1988. of activitios authorized by NRC Operating
License NPF-38 for the Waterford Steam Electric Station, Unit 3, and.to the
discussion of our findings with Mr. N. Carns and other members of your staff at
the conclusion of the inspection.
Areas examined during the inspection included transportation o'f radicactive
materials and low-level solid radioactive waste management. Within these areas,
the inspection consisted of selective examination of procedures and
.
representative records, interviews with personnel, and observations by the NRC
inspector. The inspection findings are documented in the enclosed inspection
report.
Within the scope of the inspection, no violations or deviations were identified.
However, we are concerned about the inactivity of your training program for
.
radioactive waste (radwaste) workers and personnel involved in radioactive
satorial transportation activities.
Accordingly, you are requested to respond, in writing, within 30 days t,f the
date of this letter, outlining steps taken to ensure that initial training and
'
f
retraining programs are fully implemented for personnel in the onsite radweste
l
group that satisfies NRC Inspectic's and Enf Atment Bulletin 79-19 commitments
and current industry practices.
Your respoM e .'hould address the root causes of
l
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why the previously established program wu allowed to become inactive, and the
short and long ters actions to be taken to improve and maintain the training
i
program in the future.
One unresolved item is identified in paragraph 8 of the enclosed inspection
i
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report.
!
!
The response directed by this letter is not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork ReductioT)
i
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Act of 1980, PL 96-511.
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Louisiana Power & Light Company
-2-
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Should you have any questions concerning this inspection, we wil. be pleased to
discuss them with you.
,
Sincerely,
'
t,dw Lt)
/
L. J. Callan, Director
Division of Reactor Projects
Enclosure:
Appendix - NRC Inspection Report
50-382/88-20
cc w/ enclosure:
-
Louisiana Power & Light Company
ATTN:
G. E. Wuller, Onsite
Licensing Coordinator
P.O. Box B
Killona, Louisiana 70066
Louisiana Power & Light Company
ATTN:
N. S. Carns, Plant Manager
P.O. Box B
K111ona, Louisiana 70066
Middle South Services
ATTN:
Mr. R. T. Lally
P.O. Box 61000
New Orleans, Louisiana 70161
Louisiana Power & Light Company
ATTN:
R. F. Burski, Acting Manager
Nuclear Safety and Regulatory
Affairs
317 Baronne Street
P.O. Box 60340
New Orleans, Louisiana 70160
Louisiana Radiation Control Program Director
.
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APPENDIX
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION 'V
NRC Inspection Report:
50-382/88-20
Operating License:
~
Docket:
50-382
Licensee:
Louisiana Power & Light Company (LP&L)
317 Baronne Street
New Orleans, Louisiana 70160
Facility Name:
Waterford Steam Electric Station, Unit 3 (WAT-3)
Inspection At:
WAT-3 site, Taft St. Charles Parish, Louisiana
Inspection Conducteti:
July 10-15, 1988
\\
Inspector:
b'-
7
8
17
H. D. Chade M ladiation Spec 7alist, Facilities
Date
Radiological Protection Seg: tion
dM7 M
Approved:
R.'E. Baer, Chief, Facilities Radiological
Date
Protection Section
Inspection Sunnary
Inspection Conducted July 10-15, 1988 (Report 50-382/88-20)
Ar_eas Inspected:
Routine, unannounced inspection of transportation of
radioactive materials and low-level radioactive waste (LLRW) management.
Results:
Within the areas inspected, no violations or deviations were
identified. One unresolved item concerning the transportation of radioactive
materials tras identified (see paragraph 8).
.
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DETAILS
1.
Persons Contacted
.
LP&L
- N. Carns, Plant Manager
- S. Alleman, Quality Assurance Manager
F. Davis, Nuclear Operations Support and Assessment Engineer
G. Espenan, Nuclear Operations Support and Assessment Engineer
R. Kenning, Nuclear Operations Support and Assessment Engineer
"W. LaBonte, Radiation Protection Superintendent
J. Ladet Security Supervisor, Operations
- M. Langan, Tuchnical Support Training Supervisor
D. Landeche, Health Physics (HP) Supervisor
.
M. Marler, HP Trainer
R. McLendon, Dosimetry Supervisor
- P. Prasankumar, Assistant Plant Manager, Plant Technical Services
S. Ramzy, Assistant Radiation Protection Superintendent
"J. Ridge 1, Assistant Radiation Protection Superintendent
- 0. Stevens, Radwaste Supervisor
-
Others
- T. Staker, NRC Resident Inspector
- Denotes attendance at the exit interview.
The NRC inspector also contacted other licensee personnel including
administrative, security, and quality assurance (QA) personnel.
2.
NRC Inspector Observations
The following are observations that the NRC inspector discussed with the
licensee during the exit interview on July 15, 1988 and (observation b.
which was discussed with R. Kenning) by phone on July 19, 1988.
These
obse';>vations are not violations, deviations, unresolved items, or open
items,. These observations were identified for licensee consideration for
program improvement, but the observations have no specific regulatory
requirement.
The licensee stated that the observations would be reviewed
(no comunitment was made in regard to observation b.).
.
a.
Clean Waste Release - The procedure currently in use for the testing
of gansna scintillation counting of bulk paper and plastic wastes to
be released for unrestricted use is not signed or dated.
i
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3
^
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b.
Radwaste proaram Assessments - Neither the Corporate Nuclear Support
Services Section nor the onsite Operations Support and Assessment
Group routinely performs assessments on low-level solid radwaste'and
transportation activities.
.
3.
Open Item Identified Durina This Inspection
An open item is a matter that requires further review and evaluation by
the NRC inspector.
Open items are used to document, track, and ensure
adequate follow-up on matters of concern to the NRC inspector.
The
following open item was identified:
Open Item
Title
See Paragraph
382/8820-01
Retraining of Radwaste Staff
6
4.
Unresolved Item Identified Durina This Inspection
An unresolved item is a matter about which more information is required to
ascertain whether it is an acceptable ites, a deviation, or a violation.
The following unresolved item was identified:
Open Item
Title
See Paragraph
382/8820-02
State of Nevada Identified
8
Transportations Regulation
Violations
5.
Organization and Manaaement Controls - Transportation /Radwaste
(83522/83722)
The NRC inspector inspected the licensee's staff assignments including:
organization, assignment of responsibilities, authorities, staffing,
identification and correction of problems, audits and surveillances,
commurication to employees, documentation and implementation relating to
radioactive affluents and solid wastes, and the transportation of
radioactive materials to determine adherence to commitments contained in
Sections 11 cand 13 of the Updated Final Safety Analysis Report (UFSAR),
and NRC Inspection and Enforcement Bulletin (IE8) 79-19
and compliance with Technical Specificatinn (TS) 6.2, 6.8, and 6.13.
The NRC inspector reviewed the organization of the licensee's radwaste
department which is responsible for management of solid radioactive waste
processing and transportation of radioactive materials (RAM).
The NRC
inspector also reviewed the LP&L Corporate support (Nuclear Support
Services Section) provided the WAT-3 radweste program.
-
The NRC inspector reviewed the licensea's senior management policies
(Nuclear Operations Management Manual), which included the assignment of
responsibility for AAM shipments, implementing procedures for control of
LLRW processing and transportation of RAM, the NRC approved Process
. . ~ , .
.
4
-
<
Control Program (PCP) (Procedure RW-01-210), field quality control
activities, and the NRC approved QA program (Docket:
71-0604) for
transportation activities.
The licensee utilizes an ancillary speciaT
scope QA program in conjunction with their 10 CFR Part 50, Appendix B, QA
program for ensuring quality in RAM transportation activities.
Procedures
and other documents reviewed during the inspection are listed in the
Attachment to this report.
The NRC inspector reviewed the licensee's audit program includi.ig current
and planned audits for LLRW and RAM transportation activities.
The
following audits and survelliances were reviewed:
Surveillance QS-88-055, Purchase Orders and Receipt Inspection of
'
Shipping Packages
Audit SA-87-024.1, Radwaste Processing
Audit SA-87-003E.1, Radwaste Training and Qualification
Audit A39.356-87.1, Container Products Corporation (Vendor Audit)
The licensee's audits were found to be comprehensive and included an
adequate amount of performance based objectives.
The NRC inspector noted
that while the Nuclear Operations Support and Assessment (NOSA) Group
performed operational assessments on most other activities at WAT-3, N0SA
does not perform assessments in the area of radwaste operations.
No violations or deviations were identified.
6.
Trainina and Qualification - Transportation /Radwaste (83523/83723)
The NRC inspector reviewed the licensee's training program including
adequacy of training, employee knowledge, qualification requirements,
position descriptions, technician, contract technician screening and
training, audits, and training not covered by INPO accreditation to
determine agreement with cosnitments in Section 13.2.2.8 of the UFSAR,
and NRC IEB 79-19, and compliance with the requirements of Technical Specification (TS) 6.3 and 6.4.
The NRC Inspector observed work practices and interviewed radwaste group
personnel.
The licensee's biennial requalification program for personnel
involved in radwaste processing and transportation activities was reviewed
for adequacy.
Training records for the plant staff (approximately .
21 radwaste and HP individuals) involved in the processing and
transportation of RAM were reviewed for completeness.
The NRC inspector
also reviewed the licensee's implementing procedures and lesson plans for
the training of radwaste personnel.
The NRC inspector noted (this was
also identified during a QA audit) that at least four radweste personnel
have not received any formal radwaste training since hiring on at WAT-3.
'
None of these persons appeared to have performed radwaste processing
activities other than collection of waste.
The last training for many
l
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.
.
5
.
radwaste personnel was the completion of on-the-job training checklists in
1986.
The NRC inspector noted that the licensee had provided many
individuals with required reading of procedural changes and vendor
provided training on radwaste and transportation activities in 1986 and
1987 which satisfies the biennial requalification requirements.
The NRC
inspector also noted that the lesson plans for the radwaste training
program were not current (1984 vintage) in the areas of regulatory
requirements and licensee facilities.
The iicensee training program for
radwaste workers was an item of concern in N9C Inspection
Report 50-382/85-26 ~and resulted in the issuance of a Notice of
Violation (NOV) for the failure to ensure that a contract worker received
proper training.
This area was strengthened as a result of the NOV.
The
Nuclear Training Department (NTO) staff positions responsible for radwaste
group training activities have had a high turnover rate in the past which
has resulted in the program not being maintained in a current status.
The
licensee's NTO had filled the vacant position of instructor for the
radwaste group around July 1, 1988.
The licensee's radwaste training
program will be considered an open item pending licensee implementation of
an upgraded training and requalification program for radwaste workers
,
(382/8820-01).
No violations or deviations were identified.
7.
Solid Radioactive Waste (84522/84722)
The NRC inspector reviewed the licensee's program for the control,
classification, characterization, and shipment of low-level radioactive
waste to determine agreement with the commitments contained in Section 11
of the UFSAR and compliance with the reoufrements contained in TS 3.11.3,
4.11.3; 10 CFR Parts 20.301, 20.311, 61.55, and 61.56; and the
recermendations of NRC Branch Technical Position (BTP) papers on LLRW
classification and waste form.
The NRC inspector reviewed the licensee's computerized program for
management of waste processing and packaging activities (RADMAN).
The
licensee's biannual evaluation of waste streams and development of isotope
correlation factors were reviewed.
The licensee's LLRW characterization
and classification program is well documented.
The NRC inspector reviewed
the licensee's vendor provided processes for dewatering of filters and
resins.
The licensee's PCP and the licensee's vendor's FCP for the
processing of various waste streams were reviewed for management control
over changes and revisions.
The NRC inspector reviewed selected records
of waste processing activities (resin solidification, filter dewater.ing,
dry active waste compaction, and oil solidification) for 1987.
The NRC inspector reviewed the licensee's records for LLRW shipped since
1985. The following tabulation shows the total volume of LLRW shipped for
the 1985 through 1987.
l
>* =oo
.
e
6
.
Volume Shipped (Cubic feet)
Year
Goal
Actual
Curie Content
1985
5,000
9,997
33.5
1986
6,227
6,138
37.5
~
1987
8,000
13,330*
178.2
- Included approximately 5,000 cubic feet of boric acid concentrator bottoms
held over from 1985 due to licensee efforts in evaluating onsite burial.
No violations or deviations were identified.
8.
Transportation (86721/86740)
The NRC inspector reviewed the licensee's program for transportation of
RAM, program audits, procurement and evaluation of packaging,
determination of package activity, preparation of packages for shipment,
maintenance of packages, delivery of packages to carrier, and the receipt
of RAM for compliance with the requirements of 10 CFR Parts 20.205 and
20.311; 10 CFR Part 71; and Department of Transportation (DOT) regulations
(49 CFR) incorporated by 10 CFR Part 71.
,
1
The NRC inspector reviewed 30 shipping records from the 1986 and 1987
period for completeness and accuracy.
The licensee's authorization to
utilize specific shipping packages was verified.
The NRC inspector
reviewed the documentation including advanced notification, package
opening and closing checklists, hazardous waste manifests, sole use
instructions, and survey records.
The NRC inspector noted that the
licensee routinely used extensive checklists for accomplishing shipments
of RAM.
The NRC inspector was informed, on July 11, 1988, by the licensee, that
LP&L had been notified by the state of Nevada that several violations of
DOT and burial site requirements had be identified during inspection of
two of the licensee's waste shipments to the Beatty, Nevada, burial site
(May 1988, Radioactive Shipment Record (RSR) 88-1008 and June 1988,
RSR 88-1010).
The violations identified by the state of Nevada included
radiation dose rates on waste containers significantly greater than
shipping records indicated, a waste container (strong tight package for
low-specific-activity shipment (s)) was found to have a %-inch hole in it
(manufacturing defect), improper location of DOT required placard,
illegible manifest copies, and the bracing used in a sole-use enclosed
<
trailer-van came loose and allowed the load to shif t.
The 1.icensee had
not fully investigated each of the apparent violations at the time of this
inspection.
The licensee had instituted an immediate inspection of waste
containers used for the shipment of dry active waste (OAW).
The licensee
determined that several of the onsite ready for use Container Product
Corporation's B-25 containers (steel boxes of approximately 95 cubic feet
capacity) contained manufacturing defects.
These containers are not
l
!
required to be DOT approved or NRC certified.
The hole in the B-25
.
_ _ _
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.>=%.
, .
container, founo by the state of Nevada, was the result of a weld
burn-through that was painted over at the manufacturing facility and was
not readily identifiable during the licensee's proceduralized preuse ,
inspection of the container.
At the time of this NRC inspection, the
licensee had already instituted corrective actions concerning potential -
defects in waste containers used for DAW packaging and had revised their
receipt inspection program for strong, tight containers of all makes.
The
licensee informed the NRC inspector by telephone on July 18, 1988, that
preliminary investigation of the apparent high dose rates on waste
containers may be the result of a state of Nevada mix up involving another
shipper's material and not LP&L's.
NRC enforcement will be deferred until
all of the state of Nevada's violations have been resolved.
The
licensee's apparent violation of NRC and 00T regulations will be
considered an unresolved item pending further review by the NRC during a
future inspection (382/8820-02).
The NRC inspector noted that the licensee's QA department had just
completed a surveillance of waste packaging procurement and receipt
inspection.
The draft results of the surveillance indicated that several
deficiencies were identified in the licensee's program for these
materials.
The licensee had not experienced any transportation incidents which
caused a reduction in the effectiveness of an NRC or 00T certified
packaging since the previous inspection.
No violations or deviations were identified.
9.
Review of Periodic and Special Reports
(90713)
The NRC inspector reviewed the licensee's semiannual effluent reports for
1986 through 1987 for compliance with the requirements of TS 6.9.1.8,
6.13, and 6.15 and the recommendations of RG 1.21.
The licensee's semiannual reports for the years 1985, 1986, and 1987 were
reviewed and compared to the licensee's docuser.tation concerning
radioactive material shipments (solid LLRW disposal), PCP changes, and
modifications to the solid LLRW processing systems.
No violations or deviations were identified.
10.
Exit Interview
,
The NRC inspector met with the NRC resident inspector and licensee
representatives denoted in paragraph 1 on July 15, 1988, and sussiarizedThe
the scope and findings of the inspection as presented in this report.
licensee agreed to provide the NRC with all correspondence involving the
state of Nevada's 1988 inspection and enforcement actions concerning LP&L.
.v~..
. . - . e ._ . a
.
v. r .t. i . :ugss.r m sE o 1
56-:s213 .'
.
,.
k.OCUqE.rqf,,pg'.'I_gWED
117bF
EE*fIS,ICU
D 7E
rE : 1 c er .oppr a.t t ent _ tipnagement Man.v1
.
.
-cction
!.
Special Sco.'e Ovalits Fo11ctes
.
Chapter
5.
Radioactise Weste Management
3
12-!1-87
4100 ! 2C'2C t t LW g _ Mg gu131,
ul ume 20. Radioacti ve Waste Manaoement F r oc edur es
.
R W - 01 - 1 '." . Radioactive Waste Reduction
2
00-18-67
RU-01-2OO. Record Prop ration. Filino,
and Storage
1
RW-01-210. Process Control Program
2
07-10-87
RW-02-100. Waste Material Collection and
Handlino
4
03-25-88
RW-02-110. Waste Sample Collection and
Isotope Evaluation
3
05-18-87
RW-02-120. Handling Used Protective Clothing
O
07-14-86
RW-02-2OO. Packaging Radioactive Solid Waste
(DAW) for Disposal
5
08-20-86
RW-02-210. Radioactive Waste Solidificction
6
10-26-07
RW-00-020. Radwaste Filter Disposal
2
01-07-86
RW-00-030. Waste Material Segregation
3
06-20-88
RW-02-231. Granulating Material for Disposal
2
03-29-88
RW-02-240. Blowdown Dominerali:er Resin
O
04-07-86
Transfer
RW-02-3OO. Receipt. Storage and Loading of
2
05-23-06
Shipping Containers
RW-OO-310. Storage of Loaded Shipping
3
09-15-86
Containers
RW-02-320. Packaged Radioactive Waste
Control and Inventory
5
06-06-87
RW-00-330. Radioactive Waste Tracking
1
02-18-86
RW-02-401. Use of Radman Operating Program
O
08-07-87
RW-02-411. Use of Radman Data Manager
O
09-10-87
.
RW-02-420, Operation of the Filtrk Computer
O
05-04-87
Pr-ogr am
RW-02-430, Operation of the RAMSHP Computer
1
06-01-88
i
Program
!
RW-02-500. Radioactive Material Shipment
3
.09-15-87
RW-02-501. Radioactive Waste Shipment
1
04-08-88
RW-02-521. Type and Guantity Determination
O
05-05-87
RW-02-530. Decay Heat Calculations for
-
O
05-05-87
l
USNRC Certified Containers
O
05-04-87
RW-02-541. Hydrogen Gas Calculation
RW-02-800. Dose to Curie Conversion
1
02-18-86
RW-02-810. Waste Classification
1
02-18-86
_
._
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_
___
s w c% .
r,'t-
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3
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L.r t.e,r.
r: a s ..
9
.
se j - i l ? . LN T echnvi cc,1 c u F r u s 2 ,, Corit e c)
.
,
F - o. .c e ni for Dco,t er a no Linces
G
' m.
n o. .-
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W-Ont. LN T ertiriol oo t er F r'oce s s Cori'.* v1
F roce an. f e,r R a dw;ii t e 2:o11 d i f i c.a t t on
6
05--O" - F 7
- - e G.
Oinir tinu F- r or. ? .f u r e f or- LN
Tec tint..l oo t er, Radwe E,t e Solldificat2cn
G
U .l news,
3.su..
- 6506
-
Nr C Appr o.od Topic 1 Fsport PS-52.-6076.
05-70-85
fJUS Redwaste So11 di f i cat t ore Svstem
-
Nug j.rjar , Tr a i n,1 ng ,Dqget ment _F rgc.edyrys
t
(JTC ~57. Radweste Services Trainino Fracram
2
64-07-38
LW5fD0_EL20F
T000-000-01. Radwaste Helper Final Exam
1
01-03-96
Radwaste
TOCl-000-01. Radwaste Helper
-
Frogram Overview
1
09-26-84
Nuclear
T001-001-00. Radwaste Helper
-
Power Orientation
O
09-28-84
WAT-3 Radwaste
T001-002-00. Radweste Helper
-
Systems
G
09-28-84
Solid Radwaste
T002-000-01. Radwaste Helper
-
Compaction
1
09-28-84
-
Radwaste
T003-OO6-61. Radwaste Helper
-
Solidification
1
09-28-84
W3TOO4-OOO-OO. Radwaste Helper - Radioactive
Material Classification and
Qualification
1
04-18-80
W3TOO4-001-00. Radwaste Helper - Radioactive
04-18-83
t
Material Packaging
-
W3T004-002-00. Radwaste Helper - Marking.
Labeling. Placarding
04-18-83
Requirement for Shipments
-
W5T005-000-00. Radwaste Helper - Radioactive
04-19-83
Material Shipping Papers
-
T017-000-00. Radwaste Helper - Radioactive
O
09-28-84
Shipments
'
7018-000-00, Radwaste Helper - Dry Waste
0
03-11-85
Segregation
T901-OOO-00. Radman Software
0
08-30-84
c
00:Iberdek_ Ice 1010e_Gbesklists
~
05-02-86
-
T501-000-00. Basic Radwaste
09-08-86
T506-000-01. Radwaste Equipment Operation
-
05-02-86
T502-000-00. Handling and Control of DAW
-
05-02-86
i
T503-000-00. Packaging of DAW
-
T510-000-00. Radioactive Material /Radwaste
05-02-86
-
Shipping
07-30-86
T511-OOO-00. Contract Decon Technician Quals
-
-
-
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-lvsb&
,,c a e..:.;. ea r..w i + a n a i + .; c ., r t
. r o.o n o. .-
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Crien -rave j e,r C a s l. 14-195H. CertC
.=4
Cho.n-fJucl ear C ast 6-100B. CofC i:-e
.
.
Ltd lechnoloot es Cast US//5151e".. CotC 51 ,1
fJU$ Ces6 7-10Q. Co+C 4000
L 1 c e954e _G 9CC MP.20(1905e
-
Iriter-0+ f t re Corresoorsdencat.
S.
Develle s LF t.L ) to file. Subjects-"1E
- Bullet.tn 79-19. Fact +9tng of Low-Level Radioactive Waste for Transoort and
bur 1al". deted Julv 19
1785. Ser1e1 tJo. WOF83-2488
4
e
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e
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a
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