ML20204A421

Safety Insp Rept 50-293/86-10 on 860324-27.Violations Noted: Failure to Conduct QC of Packages Transferred to Land Disposal Facility & Adhere to Station Approved Procedure

ML20204A421
Person / Time
Site:	Pilgrim
Issue date:	05/01/1986
From:	Mark Miller, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204A416	List: ML20204A415 ML20204A419 ML20204A421
References
50-293-86-10, IEB-79-19, NUDOCS 8605120194
Download: ML20204A421 (8)

See also: IR 05000293/1986010

Text

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, U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-293/86-10

Docket No. 50-293

4

License No. OPR-35 Priority Category

Licensee: Boston Edison Company M/C Nuclear

25 Braintree Hill Office Park

Braintree, Massachusetts 02199

Facility Name: Pilgrim Nuclear Power Station

Inspection At: Plymouth, Massachusetts

Inspection Conducted: March 24- 27,1986

Inspectors: k aAlv h 42f4A

M. Miller, Radfation Specialist

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Approved by: _

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W. Pasciak, Chief, Effluents Radiation 'dite

Protection Section

Inspection Summary: Inspection on March _24-21 1986 (Report No. 50-293/86-10).

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

inspector of the licensee's radioactive waste operation, packaging and trans-

portation program including, previously identified items, quality assurance /

quality control, package selection, and shipment of radioactive materials.

Results: Two apparent violations were identified: failure to conduct a

quality control function, paragraph 4.0, and failure to adhere to a station

approved procedure, paragraph 6.0.

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DETAILS

1.0 Licensee Personnel

• J. Seery, Acting Station Manager

• T. Sowdon, Radiological Section Manager

• B. Eldredge, Acting Chief Radiological Engineer

• F. Famulari, Quality Control Group Leader

• J. Mattia, Quality Assurance Audit Group Leader

• R. Schuler, Assistant Chief Radiological Engineer-Radwaste

• M. Bonnett, RP Supervisor-Shipping & Handling

P. Cormier, Senior Nuclear Training Specialist

L. Dooley, Technical Training Supervisor

• J. Poorbaugh, Senior QA Engineer

T. Sanpere, Senior QC Engineer

• M. Andrews, QC Engineer

• L. Beckwik, Plant Engineer

The inspector also contacted other licensee and contractor personnel.

1.1 NRC personnel

• H. Eichenholz, Senior Resident Inspector

• Denotes attendance at the NRC/ licensee exit meeting on March 27, 1986.

2.0 Purpose

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The purpose of this routine inspection was to review the licensee's

transportation activities with respect to the following elements:

-Status of Previously Identified Items

-Quality Assurance / Quality Control

-Package Selection

-Shipment of Radioactive Materials

3.0 Status of Previously Identified Items

(Closed) Violations (50-293/84-13-01): Failure to have three procedures

reviewed and approved as required by technical specifications. The

licensee reviewed and approved the three contractor procedures related to

waste processing in 1984. Subsequent review by the licensee's QA group

and a consultant audit in 1984 and 1985, respectively, identified addi-

tional contractor procedures that had not been approved. The inspector

noted the licensee's QA process resolved the licensee's internal dispute

concerning the requirement to have contractor procedures approval. To

date, all radioactive waste processing and transportation procedures have

been reviewed and approved.

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(Closed) Violation (50-293/84-13-02): Failure to comply with the

conditions of C of C 6601 regarding decay heat and gas generation. The

licensee provides a radwaste supervisor sign-off for each shipment to

ensure the conditions of the C of C are being followed. With regard to

decay heat and gas generation, the licensee calculates the decay heat

load and/or vents the shipping container, as appropriate to the type and

amount of radioactive waste.

-(Closed) Violation (50-293/84-13-03): Failure to identify transport f5

packages as a component of the licensee's quality assurance program. The

inspector verified that both transport packages and High Integrity

Containers (HICs) were identified as components of the licensee's quality

assurance program, Revision E13.

(Closed) Deviation (50-293/84-13-04): Failure to fulfill commitment  ;

regarding completion of IE Bulletin 79-19 training. The inspector noted

that the licensee implements a comprehensive radioactive waste training

program for all plant staff and contractor personnel, who are involved

with waste processing and transportation.

(Closed) Inspector Follow-up Item (50-293/85-13-05): Revise procedures

checklist to include cask leak tests and cask seal conditions of C uf C

5805, Revision 13. The inspector noted that temporary procedure T 85-39

was revised to ensure the cask was leak tested and seal maintenance had

been performed. -

(Closed) Violation (50-293/86-04-01): Failure to meet packaging

requirements for low specific activity radioactive material. The

inspector determined the licensee painted the Seatrain containers to

prevent rusting and to ensure radioactive waste would be packaged in

strong tight packages. The licensee also implemented a procedure for

loading Seatrain containers which required inspection of the container

during receipt and prior to shipment. In addition, the licensee's QC

group increased its surveillance of strong tight package waste shipments.

4.0 Quality Assurance / Quality Control

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

program for the packaging and transportation of radioactive materials. A

Commission approved QA program which satisfies the applicable criteria of

Appendix B to 10 CFR 50 and which is established, maintained and executed

with regard to transport packages is acceptable to meet the requirements

of 10 CFR 71, Suopart H. The licensee elected to apply their currently

established 10 CFR 50, Appendix B, QA program to the packaging and

shipment of radioactive materials.

The Itcensee's performance relative to this criteria was determined from

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discussions with the QC Group Leader, Senior QC Engineer, Senior QA

Engineer and the Chief Radiological Engineer-Radwaste; and the QC

surveillance reports and QA audit reports for 1985 with regard to

radioactive waste processing and shipment.

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4.1 Radwaste Generator QC Program

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

10 CFR 20.311(d)(3) was determined by review of procedures for

preparing radwaste shipments, examination of radwaste and QC sign-

offs related to shipments of dewatered resins and review of QA audits

which performed independent determinations of waste classification

under 10 CFR 61.55.

Within the scope of this review, the following violation was iden-

tified:

10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires a

licensee who transfers radioactive waste to a land disposal facility

to conduct a quality control program to assure compliance with

10 CFR 61.56.

The licensee had transferred several dewatered radioactive waste

shipments to a land disposal facility during 1984 and 1985 and the

licensee had not conducted a quality control program to assure

compliance with 10 CFR 61.56, inasmuch as the licensee had not

verified that spent resin contained less than 1% liquid by volume

when the resin was in a disposal container (high integrity container) ,

designed to ensure stability.

The inspector noted as of April, 1985, the licensee did institute a

QC check-off that ensured the acceptance criteria was documented for

the applicable radwaste shipments, however, QC verification of the

dewatering process by QC staff or QC designated radwaste staff had

not been performed.

Failure to conduct a quality control program to assure compliance

with 10 CFR 61.56 represents a violation of 10 CFR 20.311(d)(3).

This item will be reviewed during a subsequent inspection

(293/86-10-01).

4.2 QC Surveillance Activities

The site QC organization provides inspections of radwaste prepara-

tin , packaging and shipping activities as well as receipt inspection

of *..ansport packages. The licensee conducts 100 percent surveil-

lance of radioactive waste snipments made in NRC approved casks. The

following QC instructions and supporting reports were reviewed:

• QCI 19.01, Revision 4, " Inspection of Low Level Radioactive

W. o r Packaging and Shipping Activities"

QCI 19.02, Revision 0 and Revision 1 (Draf t), " Receipt Inspec-

tion of High Integrity Containers"

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Selected surveillance reports for 1985.

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

The inspector noted that the QC organization generally verified the

completeness of the shipping papers and adherence to packaging

requirements and related procedures. However, the inspector noted

that the QC representative did not independently verify the accuracy

of the shipping papers. The inspector also noted that peer review by

qualified members of the Waste Management group to ensure accurate

information was not routinely completed. Problems related to this

lack of review are discussed in paragraph 6.0 of this report.

4.3 Audits

The licensee's program for audits of radwaste preparation, classi-

fication, transport packages and shipping activities was reviewed.

Audits were conducted by a qualified QA auditor and supported by

qualified technical specialist, as necessary. The inspector reviewed

the following audits and surveillances for 1984, 1985 and 1986.

Audits 84-9 (April,1984), and 85-6 (March,1985)

Surveillances 85-9.5-13 (September, 1985), and 86-2.1-3

(March,1986).

The audits and surveillances were performed to verify the station's

implementation of 10 CFR 20, 61, 71 and 49 CFR requirements and to

applicable criteria of 10 CFR 50, Appendix B were being implemented.

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

The inspector noted that audit deficiencies had been reviewed and

evaluated by licensee management. However, one finding was repeti-

tious and had not been resolved. Audit 85-6, DR 1376 identified that

transport packages and services were being procured and utilized from

a vendor without a current purchase order. The revised purchase

order was issued on July 25, 1985, to expire on December 31, 1985.

Surveillance 86-2.1-3, DR 1509, conducted March 11, 1986, identified

the same violation of 10 CFR 71.109.

The licensee stated they had instituted a document control system

to prevent this problem as well as ensuring site personnel expedite

the purchase order process. The licensee stated this deficiency would

be resolved. In addition, the licensee stated they would determine

if other services requiring adequate quality were being provided

without a current purchase order. This item will be reviewed during

a subsequent inspection (293/86-10-02).

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5.0 Package Selection

The licensee's program for selection of packages was examined against the

requirements of 10 CFR 71.87 and within the framework of the D0T require-

ments of 49 CFR Part 173.

For dry radioactive waste, the licensee used steel boxes or Seatrain

containers, as strong tight containers. Dewatered resins and radioactive

material shipments, such as irradiated reactor components, requiring the

use of an NRC Certified package (outer container) were made in vendor

supplied casks. Copies of the Certificate of Compliance including draw-

ings were available for all Type A and Type B casks in use.

Within the scope of this review, the following issue was identified:

• The inspector noted that the licensee had made radicactive waste

shipments in an approved package (Certificate of Compliance 9079),

but was shipped as package model 14-170. Model 14-170 currently is

not approved by C of C 9079.

The licensee stated they would discuss this labeling conflict with their

vendor. The inspector stated this item would be reviewed during a sub-

sequent inspection, and any subsequent shipment as package model would be

considered an apparent violation of a condition of the C of C until Cask

14-170 is approved by the NRC (293/86-10-03).

6.0 Shipment of Radioactive Materials

The transportation of licensed material was reviewed against the criteria

contained in 10 CFR 71, " Packaging and Transportation of Radioactive

Material, " 10 CFR 20.311(d)(3), " Transfer for disposal and manifests,"

and 10 CFR 61.55, " Waste Classification," and 10 CFR 61.56, " Waste Char-

acteristics "

The licensee's performance relative to these criteria was determined by

the following

a

discussion with the Assistant CRE-Radwaste and his staff;

review of fifteen shipping manifests and related documents from 1985

and 1986;

review of selected program procedures including the following:

6.9-160, Revision 20, " Shipment of Radioactive Material"

6.9-165, Revision 4, " Handling & Loading Procedure LL-50-100

Shipping Cask"

6.9-184, Revision, " Handling & Loading CNSI 1-13G"

6.9-188, Revision 0, Dewatering Bead Resin in 14-195 or Small

Liners"

6.9-190, Revision 0, " Dewatering 14-195 or Smaller Liners

Containing Powder Resin, Precoat Material or D.E."

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• 6.9-193, " Classification of Radwaste 10 CFR 61"

• 6.9-195, " Completion of Radioactive Waste Shipping Papers"

6.9-200, " DOT Classification of Radioactive Material"

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• TP 85-39, Revision 1, " Handling and Lo, ling Procedure for CNIS

3-55 Cask."

Within the scope of this review, one violation was identified,

i Technical Specification 6.8 requires that written procedures and admi-

! nistrative policies be established, implemented and maintained, that meet

or exceed the requirements and recommendations of Appendix A of Regulatory

Guide 1.33, 1972. Station approved procedure 1.3.4, " Procedures,"

- requires in Section III.A that approved written procedures be adhered to

. by all station personnel. Procedure 6.9-160, Revision 20 specifies in

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part, (1) to survey material to be packaged and to document the survey results on

i appropriate radiation survey forms, and (2) to enter the maximum radiation

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level at the surface of the package, and the total activity within the

package on the shipping manifest.

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Contrary to the above, on January 23, 1985, July 9, 1985, and

August 2, 1985, radiation surveys in support of radioactive waste

! shipments of packaged irradiated reactor components were not docu-

l mented on appropriate radiation survey forms and maps or facsimile

j with the same information, and the maximum radiation level at the surface

of the package containing dewatered bead resin or other dry radioactive

j waste was incorrect; and the total isotopic activity of an irradiated

i reactor component shipment was incorrectly listed, as 279 Curies instead

l of 379 Curies during transport. These shipments were identified as

85-06, 85-66 and 85-79, and were made on January 23, 1985, July 9, 1985,

and August 2, 1985, respectively.

The inspector stated that failure to adhere to a station approved proce-

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dure with regard to radiation surveys and indicating total isotopic

i activity represents a violations of Technical Specification 6.8.

(293/86-10-04).

i The inspector also expressed concern to the licensee that (1) a waste

classifitation error for shipment 86-16 occurrgd (identified by the

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licensee's QC representative during transit); and (2) the licensee misrepre-

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sented the waste form and quantity on the Massachusetts State Notification

Form for shipment 85-66 (indicated fiter media with activity of 200 Curies

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instead of irradiated reactor components with activity of 15,900 Curies).

These were additional examples of either inaccurate or incomplete shipping

q paper documentation.

b The licensee stated that three or four RP technicians would selectively

u rotate through the Waste Management Group to enhance implementation and

adherence to procedures. In addition, the licensee would consider the use

of computers for some aspects of manifest preparation and related docu-

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mentation.

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7.0 Exit Interview

The inspector met with the licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection on March 27, 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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