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Enforcement Conference Repts 50-213/86-04,50-245/86-06 & 50-336/86-06 on 860618.Major Areas Discussed:Violations & Program Weaknesses in Radioactive Matls Transportation Program
	ML20211N446
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	06/26/1986
From:	Davidson B, Pasciak W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20211N437	List: ML20211N432; ML20211N446;
References
	50-213-86-04-EC, 50-213-86-4-EC, 50-245-86-06, 50-245-86-6, 50-336-26-6, 50-336-86-06, 50-336-86-6, NUDOCS 8607030099
	Download: ML20211N446 (22)
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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

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Report Nos. 50-245/86-06, 50-336/86-06 and 50-213/86-04 L

l Docket Nos. 50-245, 50-336 and 50-213

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j License Nos. DPR-21 Category C

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DPR-65 Category C !

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] DPR-61 Category C

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Licensee: Northeast Nuclear Energy Company

I Connecticut Yankee Atomic Power Company

P.O. Box 270 '

Hartford, Connecticut 06141-0270

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Facility Name: Millstone Point Nuclear Power Station, Unit 1 & 2

Haddam Neck Plant

Meeting At: NRC Region I, King of Prussia, Pennsylvania

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Meeting Conducted: June 18, 1986

Prepared by: 4~o C k

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B.S. DaVi son, Radiation Specialist. ' date

Approved by: 1Is . qq

Y.I Pa: ciakT Chief, Effluents Radiation

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ProQtionSection

l Meeting Summary: Enforcement Conference at NRC Region I, King of Prussia,

, Pennsylvania, on June 18, 1986, to discuss the findings of Combined Inspections ,

) 50-245/86-06, 50-336/86-06, and 50-213/86-04. The topics discussed at this

meeting were the violations and program weaknesses in the radioactive materials

l transportation program at Millstone Point Nuclear Power Station Units 1 and 2

and at the Haddam Neck olant.

The meeting was attended by NRC and licensee management and lasted about two ,

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8607030099 860626

PDR ADOCK 05000213

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1 DETAILS

l 1. Participants

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l 1.1 Northeast Nuclear Energy Company and Connecticut Yankee Atomic Plant

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! E. J. Mroczka, Vice President, Nuclear Operations

l J. Kelley, Station Services Superintendent

E. Bireley, Licensing Engineer

3 G. Bouchard, Statien Services Superintendent

j H. Clow, Health Physics Supervisor

R. Haight, Radwaste iupe visor

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1.2 NRC Personnel '

T. Murley, Regional Administrator

J. Allan, Deputy Regional Administrator

B. Kane, Deputy Director, DRP i

J. Joyner, Chief, Nuclear Materials Safety and Safeguards

i W. J. Pasciak, Chief, Effluents Radiation Protection Section

E. C. McCabe, Chief, Reactor Projects Section No.38

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M. Kras, Reactor Engineer, Reactor Projects Section No.38

j H. Bicehouse, Radiatio'n Specialist, Effluents Radiation Protection

Section

B. S. Davidson, Radiation Specialist, Effluents Radiation Protection

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Section

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) 2. Purpose

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The Enforcement Conference was held at the request of NRC Region I to

] discuss the violations and programmatic weaknesses in the area of radio-

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active materials transportation. The discussions at this meeting focused

2 on: the identified violations and weaknesses, their significance, cause,

! and licensee corrective actions thereof; and the licensee's plans for

reviewing, evaluating, and upgrading the Radioactive Materials Trans-

j portation Program at Millstone Station and at Haddam Neck Plant.

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3. Discussion

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NRC management stated that this enforcement conference was a follow-up on

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concerns related to radioactive materials transportation and shipments at

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Millstone and Haddam Neck, to find out why problems continue to occur,

j what will be done to correct these concerns and prevent recurrence. The

licensee was requested to provide his perception of the findings presented

j in Combined Report Nos. 50-245/86-06 and 50-336/86-06 and in 50-213/86-04,

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additional qualifying information, and his plans for reviewing, evalua-

ting, and upgrading the Radioactive Materials Transportation Program at .

. Millstone. Nuclear Power Station Units Nos. I and 2, and at Haddam Neck

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4. Licensee Presentation

Millstone Nuclear Power Station:

Licensee management emphasized its commitment to improving its radioactive

materials transportation program and indicated concern over the events

described in Combined Reports Nos. 50-245/86-06 and 50-336/86-06.

Licensee management stated that they had no additional qualifying infor-

mation for the findings presented in Combined Reports Nos. 50-245/86-06

and 50-336/86-06.

Licensee personnel provided handouts which summarize their actions to the

subject inspections, including the procedure revision, reorganization and

staffing, management oversight, shipping documentation, quality assurance,

facilities and equipment, training, and radwaste processing.

This handout is included as Attachment 1.

The licensee's conclusions, Attachment 2, indicate that they view their

actions as making general improvements in the radioactive waste shipment

program at Millstone through QA/QC unvolvement, vigorous pursuant of

certain improvements previously delayed and the introduction of a new

Station Services Superintendent and Radwaste Department to obviate re-

current problems.

Haddam Neck Plant:

Licensee management emphasized its commitment to improving its radioactive

waste transportation program and indicated concern over the events des-

cribed in Report No. 50-213/86-04.

License management stated that they had no additional qualifying infor-

mation for the findings presented in Report No. 50-213/86-04.

License personnel provided a handout which summarized their actions from

the subject inspection, including improvements accomplished during

1985-86, continued training for principals in the radwaste area, QA/QC and

Radwaste handling technician, and emphasized maintenance of programmatic

compliance and improvements. Also, an ir: creased level of involvement of

QA/QC surveillance, biennial audits of the program, historical review from

1984 to present of radwaste shipments and subsequent corrections to

semi-annual reports which summarized solid waste shipment activities have

been or will be effected. These and the other measures detailed in the

attached handout are viewed by the licensee as making the improvements in

the radioactive waste shipment program at the Haddam Neck Plant necessary

to prevent recurrence of the violations and weaknesses discussed in Report

No. 50-213/86-04.

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l S. Concluding Statements

Licensee management concluded by stating that their actions initiated in

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1985 would be continued to be pursued and that this would adequately

address the concern regarding the events described in Combined Reports

! 50-245/86-06, 50-336/86-06, and 50-213/86-04,

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NRC Region I management acknowledged that the plans and actions presented '

{ appeared to be responsive to its concerns. NRC Region I management stated

, that the licensee would be informed of the need for and nature of approp-

riate enforcement action relative to the violations at a later time.

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MILLSTONE NUCLEAR PCWER STATION

UNIT NOS. 1 AND 2

RADWASTE TRANSPORTATION ENFORCEMENT CONFERENCE

JUNE 18, 1986

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AN INSPECTION BY THE NRC DURING THE WEEK OF APRIL 15, 194(6

IDENTIFIED TWO VIOLATIONS AND NINE WEAKNESSES. BECAUSE OF THE

APPARENT WEAKNESS IN THE RADIOACTIVE WASTE AREA,' ' NORTHE AST

NUCLEAR ENERGY COMPANY FORMED A "RADI0 ACTIVE WASTE

TRANSPORTATION REVIEW GROUP" TO REVIEW THE RADWASTE PROGRAM AT

THE MILLSTONE SITE.

AS A RESULT OF BOTH THE NRC FINDINGS AND THE FINDINGS OF THE

REVIEW GROUP, THE FOLLOWING ACTIONS WERE TAKEN IN 1985 - 1986.

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PROCEDURES

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O ALL RADWASTE PROCEDURES WERE REVISED TO INCLUDE- DETAILED

STEP-BY-STEP INSTRUCTIONS. THESE PROCEDURES WERE APPROVED

AUGUST 1, 1985.

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WORK PACKAGES ARE GENERATED THAT REQUIRE SIGN-OFFS FOR ALL

AREAS THAT NEED TO BE VERIFIED, I.E. VERIFICATION OF

DEWATERING, RADIATION LEVELS ON VEHICLES, PROPER

PACKAGING, PROPER PLACARDS, ETC.

l RE0RGANIZATION

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0 REORGANIZATION AT THE RADWASTE DEPARTMENT HAS BEEN

APPROVED. THE RADIATION PROTECTION SUPERVISOR -

RADIOACTIVE MATERIAL, NOW REPORTS TO THE HEALTH PHYSICS

SUPERVISOR. AN ORGANIZATION CHART IS BELOW.

HP

SUPERVISOR

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RADIATION PROTECTION

SUPERVISOR-RADI0 ACTIVE MATERIAL

(INTERIM SUPERVISOR)

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ASST RADIATION PROTECTION

SUPERVISOR-RADI0 ACTIVE MATERIAL

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(POSITION BEING FILLED)

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STATION TECHNICIAN

RADI0 ACTIVE MATERIAL

(POSITION BEING FILLED)

RADMATERIAL

HANDLERS

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STAFFING

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TO SUPPORT THE NEW RADWASTE ORGANIZATION NINE ADDIT 10Nhl

PERSONNEL ARE BEING ADDED. THE ADDITIONS ARE LISTED BELOW:

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- SEVEN RADI0 ACTIVE MATERIAL HANDLERS

- ONE STATION TECHNICIAN - RADI0 ACTIVE MATERIAL

- ONE ASSISTANT RADIATION PROTECTION SUPERVISOR -

RADIOACTIVE MATERIAL.

ALSO THE RADWASTE DEPARTMENT HEAD HAS B6EN ELEVATED TO THE

SAME STATUS AS THE HEALTH PHYSICS RADIATION PROTECTION

SUPERVISORS. THIS WILL MAKE THE POSITION A HIGHER LEVEL OF

MANAGEMENT.

ALL RADI0 ACTIVE MATERI AL DEPARTMENT JOB DESCRIPTIONS HAVE BEEN a

EVALUATED AND REVISED AS NECESSARY. ALSO JOB DESCRIPTIONS FOR

THE NEW POSITION HAVE BEEN WRITTEN AND APPROVED.

MANAGEMENT OVERSIGHT

RADI0 ACTIVE MATERI AL SHIPMENTS ARE REVIEWED BY THREE LEVELS OF

i MANAGEMENT; RADWASTE SUPERVISOR, HEALTH PHYSICS SUPERVISOR,

AND THE RADIOLOGICAL SERVICES SUPERVISOR.

DURING THE ABSENCE OF THE RADWASTE DEPARTMENT SUPERVISOR HIS

RESPONSIBILITIES ARE ASSUMED BY THE HEALTH PHYSICS SUPERVISOR.

RADI0 ACTIVE MATERIAL HANDLERS ARE NO LONGER UPGRADED TO

, SUPERVISOR LEVEL.

THE RADWASTE REVIEW COMMITTEE HAS BEEN RESTRUCTURED AND IS

HOLDING QUARTERLY MEETINGS.

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SHIPMENT DOCUMENTATION

SHIPMENT DOCUMENTS ARE CURRENTLY BEING FILED AS A UNITIZED

PACKAGE. THIS PRACTICE WAS IN PLACE DURING 1985 AND ALLOWS

EASY RETRIEVAL OF RECORDS.

QUALITY ASSURANCE

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APPLICABLE PROCEDURES HAVE BEEN REVISED TO ENSURE THAT

RADWASTE IS HANDLED AS A CATEGORY I ITEM, AS ESTABLISHED BY

THE QA TOPICAL REPORT.

! QUALITY CONTROL MONITORS ALL RADI0 ACTIVE MATERIAL SHIPMENTS

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AND PROCESSING. THEY ARE REQUIRED TO ACKNOWLEDGE HOLD POINTS

BY SIGNATURE PRIOR TO THE WORK CONTINUING.

STATION QUALITY CONTROL INSPECTORS HAVE BEEN TRAINED IN NRC,

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DOT AND BURIAL SITE CRITERIA.

, RADI0 ACTIVE SHIPMENT WORK PACKAGES HAVE BEEN REVISED TO

PROVIDE FOR VERIFICATION OF PROPER LABELING AND PLACARDING.

FACILITIES

THE RADWASTE DEPARTMENT HAS BEEN MOVED TO A SPACIOUS AREA

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WHICH PROVIDES ADEQUATE WORK SPACE.

RADI0 ACTIVE MATERI AL STORAGE AREAS HAVE BEEN ELIMINATED, l.E.

THE AREAS NEAR THE UNIT ONE TRANSFORMER.

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A MOBILE HYDRO GRIT DECONTAMINATION TRAILER HAS BEEN LEASED,

l WHICH WILL ASSIST IN THE REDUCTION OF RADI0 ACTIVE MATERIAL )

STORAGE.

A RADWASTE REDUCTION BUILDING HAS BEEN COMPLETED AND IS IN l

USE. THIS BUILDING ALLOWS FOR STORAGE AND SORTING OF

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RADI0 ACTIVE MATERIAL.

THE TOOL DECONTAMINATION AREA THAT WAS DESTROYED BY~ FIRE HAS

BEEN REFURBISHED AND IS CURRENTLY IN USE.

TRAINING

TRAINING WAS CONDUCTED BY MILLSTONE ON APRIL 16 & 17, 1985,

WHICH WAS ATTENDED BY HP TECHNICIANS, QC/0A AND RADWASTE

PERSONNEL.

NUS CORPORATION CONDUCTED TRAINING ON RADIDACTIVE MATERIAL

HANDLING ON MARCH 31 - APRIL 4, 1986 WHICH WAS ATTENDED BY

RADWASTE DEPARTMENT, QC/0A RADIOLOGICAL ASSESSMENT BRANCH AND

HEALTH PHYSICS PERSONNEL.

l THE ACTING RADWASTE SUPERVISOR ATTENDED THE CHEM NUCLEAR

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RADWASTE TRAINING SEMINAR IN MAY 1986.

THE HEALTH PHYSICS SUPERVISOR ATTENDED THE FOLLOWING SEMINARS

AND TRAINING DURING 1985-1986:

1. CHEM NUCLEAR RADIOACTIVE MATERIAL TRAINING

2. EPRI RADWASTE SEMINAR, COLUMBIA, MARYLAND

3. EPRI RADWASTE SEMINAR, SAVANNAH, GEORGIA

A TRAINING PROGRAM HAS BEEN DEVELOPED BY THE NORTHEAST

UTILITIES TRAINING DEPARTMENT. THE .FIRST CLASSES ARE

SCHEDULED FOR JULY 14-25, 1986. THESE CLASSES WILL BE

TAILORED TO MILLSTONE'S NEEDS.

RADWASTE REDUCTION

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A CONCENTRATED EFFORT WILL BE MADE DURING THE 1986 UNIT 2

REFUEL OUTAGE TO REDUCE THE AMOUNT OF RADWASTE GENERATED.

THIS WILL BE ACCOMPLISHED BY:

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ONLY ALLOW.NG MATERIAL THAT IS ABSOLUTELY NECESSARY TO

BE BROUGHT INTO CONTAMINATED AREAS

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REDUCTION OF CONSUMABLES THAT ARE BROUGHT INTO

CONTAMINATED AREAS

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PURCHASE OR RENTAL OF AN LSA BOX COMPACTOR AND SUPER

DRUM COMPACTOR IS BEING EVALUATED

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RADWASTE PROCESSING

PROCESSING OF RADWASTE (DEWATERING, SOLIDIFICATION) HAS BEEN

RETURNED TO THE OPERATING UNITS. THEY ARE RESPONSIBLE FOR THE

PROCESS AND THE RADWASTE DEPARTMENT IS RESPONSIBLE ONLY FOR

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CONCLUSIONS

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1. The actions completed have improved the radioactive waste

shipment program at Millstone.

2. The recent findings are due to an isolated case, further

discrepancies identified on past shipments and a continuing

discussion on QA/QC involvement in the process.

3. Certain improvements have been delayed in implementation. They

will be vigorously pursued to further improve the program.

4. The new Station Serv 4ces Superintendent and Radwaste Department

organization will ensure the program will not experience any

recurrent problems.

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5. The QA/QC interface in the process is appropriate and

consistent with their involvement in other similar situations

at the Station.

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CONNECTICUT YANKEE ATOMIC POWER COMPANY

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HADDAM NECK PLANT

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j RADWASTE TRANSPORTATION ENFORCEMENT CONFERENCE

JUNE 18, 1986

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THE CY RADI0 ACTIVE WASTE GROUP WAS FORMED IN 1980 AND

ORIGINALLY CONSISTED OF A SUPERVISOR AND THREE WORKERS. ITS

PRIMARY PURPOSE WAS COLLECTION AND PACKAGING OF DISPOSABLE

ITEMS IN THE RADI ATION CONTROL AREA. THIS GROUP NOW CONSISTS

OF THE RADI0 ACTIVE MATERIALS HANDLING SUPERVISOR AND TEN

RADI0 ACTIVE WASTE TECHNICI ANS, WHO HANDLE ALL DECONTAMINATION

EFFORTS, COLLECTION, PACKAGING AND TRANSPORTATION ACTIVITIES.

THE FOLLOWING IS A LISTING OF IMPROVEMENTS MADE DURING 1985-

1986 WITHIN THE RADWASTE AREA:

O PROCEDURES WERE UPGRADED TO ENSURE PROPER RECEIPT

INSPECTION OF VENDOR PROVIDED EQUIPMENT, AND PLANT

APPROVED PROCEDURES ARE USED FOR OPERATION OF VENDOR

EQUIPMENT.

O TRAINING 0F QC INSPECTORS WAS ACCOMPLISHED ON SITE TO

ENSURE ADEQUATE TECHNICAL EXPERTISE WILL BE AVAILABLE

FOR THESE REQUIRED INSPECTIONS.

O ALL RADI0 ACTIVE WASTE HANDLING PROCEDURES NOW

INCORPORATE "0A HOLD POINTS" TO INCREASE THE LEVEL OF

GA INVOLVEMENT.

O THE RADWASTE REVIEW COMMITTEE HAS INCREASED ITS

SCHEDULED MEETINGS AND WILL BECOME MORE INVOLVED IN

SURVEILLANCE OF STATION ACTIVITIES.

O ALL STATION RADWASTE PROCEDURES WERE REVIEWED FOR

ACCURACY AND CONSISTENCY REGARDING ACCEPTANCE

CRITERIA.

O SCALING FACTORS, AS RECEIVED FROM WASTE CONSULTANTS,

WERE INCORPORATED INTO STATION PROCEDURES.

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O ALL CALCULATIONS USED TO DETERMINE TOTAL SHIPMENT

ACTIVITY ARE MAINTAINED ON SITE AS' PERMANENT RECORDS.

O PROCEDURAL CONTROLS ARE IN EFFECT TO ENSURE

RECHARACTERIZATION OF WASTE STREAMS FOLLOWING ANY

CHANGES IN ACTIVITY.

0 EQUIPMENT HAS BEEN OBTAINED TO MINIMlZE WORKER'S TIME

IN RADIATION ZONES WHEN HANDLING AND PROCESSING

RADI0 ACTIVE MATERIALS.

O TRAINING / INDOCTRINATION SESSIONS ARE HELD ON A ROUTINE

BASIS TO FAMILIARIZE RADWASTE TECHNICIANS WITH CURRENT

OPERATING METHODS.

0 OUR RADIOLOGICAL INCIDENT REPORT PROCEDURE WAS

q UPGRADED TO REQUIRE MORE PROMPT MANAGEMENT

i NOTIFICATION AND ALSO TO INCLUDE AN INDEPENDENT REVIEW

IF WARRANTED.

O THE HEALTH PHYSICS DEPARTMENT GENERATED AN INSTRUCTION

TITLED "OUALITY ASSURANCE PROGRAM FOR RADWASTE PACKAGE

CALCULATIONS"., THIS IS A " COOKBOOK" PROCEDURE TO

ALLOW AN INDEPENDENT REVIEW OF THE METHODS,

CALCULATIONS AND CLASSIFICATION OF RADWASTE MATERIAL

TO BE DISPOSED OF AT AN APPROVED DISPOSAL SITE.

O IN THE AREA 0F CONTINUAL TRAINING, WE HAVE

ACCOMPLISHED THE FOLLOWING:

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1. THE RADI0 ACTIVE MATEP.IALS HANDLING SUPERVISOR,

HEALTH PHYSICS SUPERVISOR, RADIATION PROTECTION

SUPERVISOR AND THE STATION SERVICES SUPERINTENDENT

ATTENDED A WEEK LONG COURSE OFF SITE ON

RADIOACTIVE MATERI AL PROCESSING. THIS COURSE WAS

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" RADIOACTIVE WASTE PACKAGING, TRANSPORTATION AND

DISPOSAL WORKSHOP" GIVEN BY CHEM-NUCLEAR AT

CHARLESTON, SC.

2. AN IN-HOUSE TRAINING COURSE WAS PRESENTED TO THE QA/QC

DEPARTMENT AND RADWASTE HANDLING TECHNICIANS.

O AN EXTENSIVE DECONTAMINATION PROGRAM COMMENCED IN 1985 AND

RESULTED IN APPROXIMATELY 15,000 SQUARE FEET OF

CONTAMINATED SPACES BEING RELEASE FOR PERSONNEL ACCESS

WITHOUT PROT D ION CLOTHING.

O A FILL HEADER WAS PURCHASED FOR USE WITH THE HIGH

INTEGRITY CONTAINERS.

O WE HAVE ORDERED THE REMOTE LIFTING DEVICE FOR LINERS.

THIS RECENTLY BECAME AVAILABLE AND WILL MINIMlZE PERSONNEL

EXPOSURE WHEN HANDLING RADIOACTIVE CONTAINERS.

O DUE TO SAFETY CONCERNS WHEN WORKING AROUND SHIPPING CASKS,

WE ALSO DESIGNED AND HAD FABRICATED A PLATFORM TO ALLOW

SAFE-WORKING CONDITIONS AROUND RADIOACTIVE SHIPPING CASKS.

O A SUPPORT STRUCTURE WAS ALSO FABRICATED TO HOLD LSA BOXES ,

DURING INSPECTION FOR FREE STANDING LIQUID PRIOR TO

SHIPMENT.

O AN OIL FILTRATION SYSTEM WAS IMPLEMENTED IN 1985 AND ,

ACHIEVED A ll7 PERCENT REDUCTION IN CONTAMINATED OIL ON

SITE.

O STATION PROCEDURES DEALING WITH THE METHOD OF

CONTAMINATION CONTROL AT THE WORKSITE WERE UPGRADED TO

ASSIGN RADWASTE TECHNICIANS TO SET UP THE WORK AREA

BOUNDARIES TO MINIMlZE LOSS OF CONTROL AND CONTAIN

RADIOACTIVE MATERIALS.

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0 DURING MAJOR OUTAGES, RADWASTE TECHNICIANS ARE ASSIGNED

OVERSEE ALL GENERATION ACTIVITIES AND KEEP

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CONTAMINATION AS LOW AS REASONABLY ACHIEVABLE.

O A MAJOR ADDITION TO OUR PROCESSING IS CONSTRUCTION AND

UTILIZATION OF A RADWASTE BUILDING AT CY. THIS BUILDING

WILL CONSOLIDATE MOST OF OUR - ACTIVITIES IN ONE CENTRAL

LOCATION. WE WILL HAVE THE WASTE COMPACTOR, WASTE

SHREDDER AND SORTING AREAS ALONG WITH A WOOD SANDER

AVAILABLE FOR WASTE MINIMlZATION. ADDITIONALLY, IND0OR

STORAGE CAPABILITIES WILL BE GREATLY INCREASED.

O THE RADI0 ACTIVE MATERIALS HANDLING SUPERVISOR HAS BEEN

ASSIGNED THE CONTROL OF ALL STAGING MA;ERI ALS TO MINIMlZE

THE ACCUMULATION OF THESE MATERIALS WITHIN THE

RADIOLOGICAL CONTROL AREA.

O WE PRESENTLY TRANSMIT TRENDING CHARTS TO STATION AND

CORPORATE MANAGEMENT ON ALL SIGNIFICANT PARAMETERS

INVOLVING RADWASTE. SOME EXAMPLES OF THIS ARE WASTE

GENERATION, SPACE CONTAMINATION CONTROL, WASTE SHIPMENTS,

ETC. THESE CHARTS ARE SUBMITTED MONTHLY TO UPPER

MANAGEMENT AND POSTED THROUGHOUT THE STATION.

SUMMARY:

CONNECTICUT YANKEE WILL CONTINUE T0:

1. MAINTAIN ITS RADIOACTIVE MATERIAL ' HANDLING PROGRAMS IN

COMPLIANCE WITH APPLICABLE REGULATIONS AND, l

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2. AGGRESSIVELY SEEK AND IMPLEMENT PROGRAM IMPROVEMENTS.

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SUMMARY OF PROCEDURE

NEO 6.07 :

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CONNECTICUT YANKEE

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IMPLEMENTATION PROCEDURES

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BACKGROUND

AS A RESULT OF INPUT FROM VARIOUS SOURCES, IT BECAME APPARENT

WITHIN NU THAT THERE WAS A GAP BETWEEN THE QA TOPICAL REPORT

AND THE ONGOING RADWASTE QA EFFORTS AT THE STATIONS. AN ADHOC

COMMITTEE WAS FORMED TO ADDRESS THIS PROBLEM.

ThE RESULT OF)

THEIR NINE-MONTH EFFORT WAS NE0 6.07 " QUALITY ASSURANCE AND

QUALITY CONTROL IN STATION RADI0 ACTIVE MATERIAL PROCESSING,

CLASSIFICATION, PACKAGING, AND TRANSPORTATION". THIS

PROCEDURE, WHICH WAS APPROVED 3/25/86, DESCRIBES A COMPLETE

RADWASTE QA PROGRAM, INCLUDING CORPORATE OVERVIEW, FOR USE AT

BOTH STATIONS.

PURPOSE

SOURCE DOCUMENT FOR NU'S RADI0 ACTIVE WASTE QUALITY ASSURANCE

PROGRAM PROVIDES THE QUALITY ASSURANCE PROGRAM REQUIREMENTS OF

10CFR71 " PACKAGING AND TRANSPORTATION OF RADIOACTIVE MATERIAL"

SUBPART H "0VAlllY ASSURANCE" AND 10CFR20 " STANDARDS FOR

PROTECTION AGAlllST RADIATION" SECTION 20.311(D)(3) QUALITY

ASSURANCE FOR WASTE CHARACTERISTICS AND CLASSIFICATION.

THIS PROCEDURE DELINEATES THE QUALITY ASSURANCE REQUIREMENTS

FOR ENSURING:

O PROPER RADI0 ACTIVE WASTE CHARACTERISTICS (10CFR61.56)

0 PROPER RADI0 ACTIVE WASTE CLASSIFICATION (10CFR61.55)

O PROPER PACKAGING OF RADI0 ACTIVE WASTE (10CFR71) I

0 PROPER TRANSPORTATION OF RADI0 ACTIVE WASTE (10CFR71,

49CFR)

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AREAS COVERED

SECTION 6.1 RECEIVING FACILITY LICENSE (10CFR30.41) AND

RECEIPT OF PACKAGES (10CFR20,205)

COVERS THE REQUIREMENT FOR CYAPC0 TO HOLD COPIES OF THE

RECEIVING FACILITIES' LICENSES. DETAILS THE REQUIREMENTS OF

10CFR20.25 ON RECEIPT AND HANDLING OF PACKAGES.

SECTION 6.2 WET WASTE SOURCE STREAMS -

PROCESS CONTROL

PROGRAMS (10CFR61.56)

PROVIDES QA REQUIREMENTS FOR THE PROCESS CONTROL PROGRAM USED

TO ENSURE PROPER WASTE CHARACTERISTICS AS REQUIRED BY

10CFR61.56. DIRECTS DA TO PROVIDE DOCUMENTED MEASURES TO

VERIFY COMPLIANCE WITH THE PROCESS CONTROL PROGRAM.

SECTION 6.3 DRY ACTIVE WASTE SOURCE STREAM

DELINEATES REQUIREMENTS FOR DAW SORTING, COMPACTING AND

SURVEYING. ASSIGNS QA TO VERIFY COMPLIANCE.

SECTION 6.4 SPECIAL PROJECTS WASTE SOURCE

MAKES PROJECT LEADERS RESPONSIBLE TO ENSURE THAT RADWASTE

GENERATED BY THEIR PROJECT IS HANDLED PROPERLY. REQUIRES QA

TO VERIFY COMPLIANCE.

SECTION 6.5 WASTE SAMPLING AND ANALYSIS

DEFINES SAMPLING AND ANALYSIS REQUIREMENTS AND DIRECTS QA TO

VERIFY COMPLIANCE.

.

( . .

?.

.

SECTION 6.6 WASTE CLASSIFICATION (10CFR61.55)

DEFINES QA REQUIREMENTS FOR WASTE CLASSIFICATION ACTIVITIES

AND TO VERIFY COMPLIANCE. -

SECTION 6.7 RADI0 ACTIVE MATERIAL PACKAGING AND SHIPPING

DIRECTS QA TO VERIFY THAT RADI0 ACTIVE MATERIAL PACKAGING,

LABELING AND SHIPPING ACTIVITIES ARE PERFORMED IN ACCORDANCE

WITH NRC, DOT AND STATE REQUIREMENTS.

SECTION 6.8 APPRAISALS

TASKS MANAGER RAB CORPORATE TO HAVE APPRAISALS PERFORMED ON

THE STATION RADWASTE PROGRAM.

SECTION 6.9

TASKS MANAGER NUSCO QA TO HAVE PERFORMED:

0 BIANNIAL AUDITS OF RADI0 ACTIVE MATERIAL SHIPPING

PROGRAM.

O AUDITS OF VENDOR PROGRAMS.

.

_

.-

-

!. .

.

CONNECTICUT YANKEE IMPLEMENTING PROCEDURES

(APPROVED 6/10/86)

.

ACP 1.2-2.9 " QUALITY ASSURANCE AND QUALITY CONTROL IN

STATION RADI0 ACTIVE MATERIAL PROCESSING,

CLASSIFICATION, PACKAGING AND TRANSPORTATION"

THIS IS CYAPCO'S BASIS DOCUMENT. IT IMPLEMENTS SECTIONS 6.1

THROUGH 6.7 0F NE0 6.07. I

ACP 1.2-13.5 " ENTRY AND EXIT FROM STATION OF TRANSPORTER FOR

NUCLEAR BY-PRODUCTS MATERIAL (RAD WASTE)"

THIS IS CYAPCO'S PROCEDURE FOR SHIPPING RADIDACTIVE MATERI AL

IN TYPE 'B' PACKAGES OR AS RADI0 ACTIVE LSA (EXCLUSIVE USE).

THIS PROCEDURE HAS BEEN IN EFFECT FOR A LONG TIME AND COVERS

THE MAJORITY OF CYAPCO'S SHIPMENTS. IT WAS REVISED TO COMPLY

WITH NE0 6.07.

ACP 1.2-13.7 " SHIPPING QUALITY CONTROL OF RADIOACTIVE

MATERIAL SHIPMENTS"

THIS PROCEDURE COVERS ALL SHIPMENTS OF RADI0 ACTIVE MATERIAL

NOT COVERED BY ACP 1.2-13.5.

ML20211N446

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