ML20203F504
| ML20203F504 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/14/1986 |
| From: | Clemons P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203F475 | List: |
| References | |
| 50-334-86-05, 50-334-86-5, NUDOCS 8604250168 | |
| Download: ML20203F504 (9) | |
See also: IR 05000334/1986005
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-334/86-05
Docket No. 50-334
-- License No.
Category
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Licensee: Duquesne Light Company
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Post Office Box 4
-Shippingport, Pennsylvania 15077
Fac t'li ty ' Name : Beaver Valley Power Station, Unit 1
Inspection At:
Shippingport, Pennsylvania
Inspection Conducted: March 10-14, 1986
Inspector:
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P. Clemons, Radiation Specialist
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Apprcved by:
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W. Pasciak, Chief, ERPS
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Inspection Summary:
Inspection on March 10-14, 1986 (Report No. 50-334/86-05)
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Areas Inspected:
Routine, unannounced safety 4,.,pection of the licensee's
radioactive materials transportation program including: management control,
shipments of licensed material, training, procedures, audits, package
selection, quality assurance, Part 61, and quality control.
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Results:
Four apparent violations were identified: (1) packages were not-
strong, tight, packages, paragraph 4; (2) Q.A. auditors were not adequately
trained, paragraph 5; (3) procedure was not reviewed every two years as
required, paragraph 6, and (4) licensee did not have a legible copy of a
drawing, paragraph 7.
8604250168 860421
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ADOCK 05000334
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. DETAILS
1.0 Persons Contacted
1.1 Licensee Personnel
J. Sieber, Senior Manager, Beaver Valley Unit #1
N. Tonet, General Manager-
-T. Jones,. General Manager
W. Lacey, Plant Manager
J.-Kosmal, Manager, Radiological Controls
C. Ewing, Manager, Quality Assurance-
K. Grada, Manager. _
D. Blair, Director, Radiological Health Services
D. Girdwood, Director, Radiological Operations
M. Vento,_ Director, Radiological Engineering
C. Haney, Director, Technical and Craft Training
D. Hunkele, Director, Quelity Assurance Operations
S. Fenr.er, Director, Operations Quality Control
M. Perger, Quality Control Jupervisor
F. Lipchick, Senior Licensing Supervisor
G. Sovick, Senior Licensing Supervisor
D. Roman, Quality Assurance Maintenance Supervisor
M. Somerville, Senior Health Physics . Specialist
A. Castagnacci, Senior Health Physics Specialist
H. Jenkins, Rad Waste Coordinator
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1.2 State Personnel
~R. Janati, Nuclear Engineer
S. Maingi, Nuclear Engineer
1.3 NRC-Personnel
W. Troskoski, Senior Resident Inspector
Other licensee personnel were contacted and interviewed during this
inspection.
2.0 Purpose
The purpose of this routine inspection was to review the licensee's basic
transportation program with respect to the following elements:
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Review of management controls;
Review of shipments of license material;
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Review of-training;
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Review of procedures;
Review of audits;
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Review of package selection;
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Review of quality assurance;
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Review of quality control; and
Review ef Part 61.
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3.0 Management Controls
The licensee has defined the responsibility for~ radioactive solid waste
management in Appendix 8 of the Beaver Valley Power Station Radiological
Control Manual. The responsibility has been divided between the Radio-
logical Controls Group, the Station Operations Group and the Station
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Chemistry Group. No single group is charged with the overall responsi-
bility to assure that the solid wa>te management program is being im-
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plemented in accord with the appropriate requirements.
Fragmented responsibilities is a potential prime factor in the loss of
management controls in the problem areas identified in this report.
4.0 Shipment of License Material to a Vendor
Several shipments of radioactive material were reviewed against the
criteria contained in 10 CFR 71 " Package And Transportation Of Radioactive
Material", and 49 CFR Parts 170 through 189.
The licensee's performance relative to these criteria was determined by
discussions with personnel in the Radiological Controls Group, personnel
in the Station Operations Group, and by reviewing appropriate documents.
Within the scope of this review, the following violation was identified.
On October 17, 1985, Duquesne Light Company shipped 43.756 millicuries of
licensed material, designated as low specific activity (LSA), in the form
of solid / metal oxides - activation and fission products to Quadrex HP5
Inc., located in Oak Ridge, Tennessee. The shipment was made in a common
carrier exclusive use vehicle, consisting of twenty-nine 55 gallon drums
containing misc'llaneous tools, components, electrical cords, hoses and
scrap contaminated with the licensed material.
The shipment was received by the consignee on October 18, 1985. On
October 21, 1985, the barrels were removed from pallets and inspected.
The inspection consisted of selective surveys and examination of the
55 gallon drums.
During this operation, the following was observ J:
Drum No
14, containing 0.021 millicuries, had t e r holes that penetrated
to the inside of the drum.
The holes were approximately 1/4 inch in
diameter, and were located about one inch below the barrel lid locking
ring, and Drum No. 24, containing 1.03 millicuries, was punctured on the
bottom. The punctures consisted of two " slashes" about 3 inches long by
1/4 inch wide. The " slashes" were covered with yellow tape.
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10 CFR 71.5 prohibits delivery of licensed material to a carrier for
transport unless the licensee complies with appliable regulations of the
Department of Transportation in 49 CFR Parts 170-189.
49 CFR
173.425(b)(1), " Transport requirements for low specific activity (LSA)
radioactive materials" states " Package shipments of LSA material
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consi~gned as exclusive use... must be packaged in strong, tight packages
so that there will be no leakage of radioactive material under conditions
normally incident to transportation."
On March 11, 1986, licensee representatives informed the inspector that
Quality Control personnel did not inspect the drums as they were loaded
onto the vehicle. The inspector asked if any licensee personnel
inspected the drums as they were being loaded onto the vehicle. The
inspector was told that no licensee personnel specifically inspected any
of the drums as they were being loaded.
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The inspector asked if the licensee could verify that the contents of
Drums 14 and 24 were wrapped. Licensee personnel stated that they could
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not verify that the contents of the drums were wrapped.
The shipment of licensed material in drums that were not strong, tight
packages represents a violation of 10 CFR 71.5 (86-05-01).
5.0 Audits
The licensee's program for the auditing of transport packages was
reviewed against the criteria contained in Criterion II " Quality
Assurance Program", and Criterion XVIII, " Audits", of the licensee's
Quality Assurance Program.
The licensee's performance relative to these criteria was determined by
discussion with the Quality Assurance Maintenance Supervisor, the Quality
Assurance Surveillance Supervisor, and by reviewing appropriate docun.ents.
Within the scope of this review, the following violation was identified.
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The inspector determined that an audit was conducted by three Quality
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Assurance Maintenance personnel during the period June-July 1985, and the
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auditors were not appropriately trained.
10 CFR 71.101(b) requires each licensee to establish a quality assurance
program for packages.
10 CFR 71.101(f) states that a Commission approved
quality assurance program that satisfies the applicable criteria of Ap-
pendix B, Part 50 of this chapter, and which is established, maintained,
and executed with regard to transpo.-t packages will be accepted as sat-
isfying the requirements of paragraph (b) of this section.
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Criterion XVIII of Appendix B, Part 50 states, in part, that_"A
comprehensive system of planned and periodic audits shall be carried out
to verify compliance with all aspects of the quality assurance program
and to determine the effectiveness of the program.
The audits shall be
performed... by appropriately trained personnel..."
Criterion II of Appendix B, Part 50, States, in part, that "...The program
shall provide for indoctrination and training of personnel performing
activities affecting quality as necessary to assure that suitable
proficiency is achieved and maintained..."
The inspector determined that .each auditor had received two days of
training in transportation activities, and this minimal training would not
assure that suitable proficiency would be achieved and maintained inasmuch
as the material presented was too voluminous and complex.
The failure to train quality assurance personnel as necessary represents
a violation of 10 CFR 71.101(b) [86-05-02].
The licensee is committed to ANSI /ASME N45.2.23-1987 which states in Item
2.2, "The responsible auditing organization shall establish the audit
personnel qualifications and the requirements for the use of technical
specialists to accomplish the auditing of the quality assurance programs.
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. Auditors shall have, or be given,
appropriate training or orientation to develop their competence for
performing required audits."
The auditors performing the audit did not appear to have the experience or
training that is required to perform such an audit.
6.0 Procedures
The adequacy and effectiveness of certain of the licensee's procedures
were reviewed against the criteria contained in Technical Specification 6.8, " Procedures".
The licensee's performance relative to these criteria was determined by
discussions with the Manager, Radiological Controls, the Radwaste Coor-
dinator, a Senior Health Physics Specialist, and by reviewing procedures.
Within the scope of this review, the following violation was identified.
The inspector determined that the licensee used Procedure No. F0-OP-004,
" Dewatering Procedure For The 24-Inch Diameter Pressure Demineralizer
Vessel Containing Ion Exchange Resins" on at least one occasion during
1985. The inspector noted that the procedure was last approved by the
Operations Safety Review Committee on June 15, 1983.
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TechnicalSpecification6.8,"Proceduresi,requiresthatproceduresbe
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establishad, implemented, and maintained.
Item E.12 of Station
Administration Procedure, Chapter 6, " Radiological Control Group
Administration", developed pursuant ta the above, states, " Procedures
shall be reviewed at a minimum inter,al of every two years, or after
significant changes or incidents, to determine'if changes to the
procedures are necessary or desirable..."
The Radwaste Coordinator infctmed the inspector that this was a vendor's
procedure that was being used. The inspector stated that procedures
being used by the licensee in their radwaste transportation activities,
whether vendor procedures, or otherwise, would be expected to follow the
requirements of reviewing procedures every two years.
The failure to
follow the review requirement of Station Administration Procedure,
Chapter 6, represents a violation af procedures required by the Technical
Specifications (86-05-03).
7.0 Shipment of License Material for Burial
A shipment of licensed material to a burial site was reviewed against the
criteria contained in 10 CFR 71.12, " General license: NRC approved
package."
The licensee'< performance relative to these criteria was determined from
discussions
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documents.
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Within the scope of this review, the following violation was identified.
It was determined that the licensee shipped 29.14 Curies of licensed
material to a burial site on April 23, 1985 in package Model No. CNS
6-80-2,. Certificate of Compliance (C of C) No. 9111.
10 CFR 71.12(a) states, "A general license is hereby issued to any 11-
censee of the Commission to transport, or to deliver to a carrier for
transport, licensed material in a package for which a ... certificate of
compliance...has been issued by the NRC.
10 CFR 71.12(c)(1) states,
"This general license applies only to a licensee who has a copy of the
... certificate of compliance...and has the drawings and other documents
referenced in the approval..."
The inspector determined that the license did not have the drawing
referenced in the C of C.
The Rad Waste Coordinator had a reduced copy of
a drawing, but the drawing could not be verified as the referenced drawing
because the drawing identification number was not legible.
The failure to have the required drawing represents a violation of 10 CFR 71.12(86-05-04).
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8.
Package Selection
The licensee's program for selection of packages was reviewed against the
requirements of 10 CFR Parts 71.12, and the DOT requirements of 49 CFR
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Part 173.
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The licensee's performance relative to these criteria was determined by
discussion with the Rad Waste Coordinator and by review of appropriate
documents.
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Copies of the Certificate of Compliance were available for all NRC
approved packages that were in use.
Within the scope of this review, no violations were identified.
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Quality Assurance
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The licensee's quality assurance program for transport packages was
reviewed against the criteria contained in Appendix B, Part 50. The
licensee's performance relative to these criteria was determined by
discussion with the Quality Assurance Maintenance personnel and by reviewing
the Operations Quality Assurance Program.
Within the scope of this review, the following was identified.
Criterion II of Appendix B states, in part, that the licensee shall
identify the structures, systems, and components to be covered by the
quality assurance program. The licensee has identified transport packages
as a Category I Item in Appendix B of the Operations Quality Assurance
Program.
The inspector reviewed the Purchase Order that had been issued to a
vendor purchasing the use of transport packages to determine the
requirements imposed upon the vendor by the licensee. The inspector noted
that the purchase order contained the following notation:
"3/C".
The Materials Control Supervisor stated that the inclusion of this nota-
tion on the purchase order meant that transport packages did not require
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quality assurance documentation or Quality Assurance / Quality Control re-
ceipt inspection.
The Materials Control Supervisor also stated that if
the purchase order had contained the Category I notation, transport
packages would receive Category I attention upon receipt.
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The Rad Waste Coordinator informed the inspector that transport packages
are inspected upon receipt, but the inspector determined that the licensee
does not have procedures, or any other means, of requiring transport
packages to receive Quality Assurance / Quality Control inspection upon
receipt.
This item will be reviewed in a subsequent inspection (86-05-05).
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10. Quality Control
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In. response to a violation cited in Inspection Report 50-334/81-31 the
~ licensee stated, "The BVPS Operating Manual, Chapter 18, ' Solid Waste
Disposal System' will be revised to provide for QC inspections to assure
that packages do not contain free standing liquids greater than 1*4 of the
waste volume and to verify the stability of the waste form."
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The inspector noted that Section E, " Solidification of Spent Resin", of
Chapter 18 had been revised as follows:
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"Q.C. will be notified prior to solidification."
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The Rad Waste Coordinator informed the inspector that Quality Control
personnel were witnessing various steps in the solidification and dewatering
processes.
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.The inspector asked the Rad Waste Coordinator if Quality Control had been
informed of the change in the procedure and if they had received training
in the procedure change.so that they would know what was expected of
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them. The Rad Waste Coordinator stated that_ he did not knou if Quality
Control had been informed of the change, and neither did he know if they
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had been trained in the procedure.
The inspector asked the Quality Control Inspectors to explain what they
did to assure compliance with 10 CFR 61.56. The inspectors stated that
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in the solidification operation they only looked into the top of the
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container to verify that they could not see free standing water.
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case of dewatering, the inspectors stated that after all operations were
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completed, they inspected a bottle to assure that the bottle contained
less than 500 milliliters of water.
Neither effort represents an acceptable quality control program to assure
compliance with 10 CFR 61.56.
The inspector determined that the inspectors had not been trained in the
procedures and they were not informed as to what was expected.
This item is still open until more positive steps are taken to assure the
required quality control is implemented.
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11.
Part 61
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The inspector reviewed the licensee's Process Control Program (PCP) as
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applicable to 10 CFR 61.56, " Waste Characteristics", during this
inspection.
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The inspector noted that the licensee submitted a copy of their process
control program to NRR in resfonse to Generic Letter 84-12 in a letter
dated December 13, 1984. NRR responded on January 25, 1985, and said
"...We find that this PCP generally complies with current NRC criteria
and therefore is acceptable on an interim basis for use with the Beaver
Valley Technical Specification 3.11.3.1."
The inspector determined during this inspection that Duquesne Light
Company had developed another process control program that had not been
submitted to NRR.
The title of this document is:
Duquesne Light Company
Beaver Valley Power Station
Operating Manual
Chapter 18
Unit #1
QA Category
Incorporated in this PCP was Appendix A which contained a vendors test
dated April 1985 for Part 61 Waste Form comp' lance. This PCP had not been
submitted to NRR at the time of this inspection, and neither had the
licensee performed evaluations to assure that the vendors data would
assure compliance with the regulations.
The Rad Waste Coordinator stated that an evaluation had been performed
"sometime" ago. The inspector stated that he would review appropriate
data that would substantiate that an evaluation has been performed.
On March 3, 1986, the Rad Waste Coordinator provided the inspector
information that was supposed to verify that an evaluation of the vendors
test data had been done. The information provided was not acceptable
because it was generated on March 3, 1986, was informal, the information
was not dated, and neither was it signed.
This item will be reviewed in a subsequent inspection (86-05-06).
12. Exit Interview
The inspector met with the licensee representatives (denoted in Para-
graph 1) at the conclusion of the inspection on March 14, 1986. The
inspector summarized the scope of the inspection and findings.
At no time during this inspection was written material provided to the
licensee.
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