ML20211Q286
| ML20211Q286 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 12/12/1986 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8612190234 | |
| Download: ML20211Q286 (2) | |
See also: IR 05000213/1986004
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DEC 121986
Docket Nos. 50-245
50-336
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50-213
Northeast Nuclear Energy Company
ATTN: Mr. J. F. Opeka
Senior Vice President - Nuclear
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Engineering and Operations Group
P. O. Box 270
Hartford, Connecticut 06141-0270
Gentlemen:
Subject: Combined Inspection Nos. 50-245/86-06, 50-336/86-06 and
50-213/86-04
We have reviewed your letter dated November 19, 1986, in response to our re-
quest for updates on your program improvement plan in your radioactive waste
preparation, packaging and shipping program. We have noted that actions on
these procedures governing radioactive waste solidification are reported to be
complete and progress has been made on the other improvement items.
Thank you for informing us of the progress on these corrective and preventive
actions as documented in your letter. These actions will be examined during a
future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
OM r'v1 CI- d N8
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MetJMomas T. Martin, Director
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Division of Radiation Safety
and Safeguards
cc:
E. J. Mroczka, Vice President, Nuclear Operations
W. D. Romberg, Station Superintendent
D. O. Nordquist, Manager of Quality Assurance
R. T. Laudenat, Manager, Generation Facilities Licensing
R. Graves, Plant Superintendent
Gerald Garfield, Esquire
Pubite Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of Connecticut
0FFICIAL RECORD COPY
RL MILLSTONE - 0001.0.0
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Region I Docket Room (with concurrences)
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Management Assistant, DRMA (w/o enc 1)
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DRP Section Chief
M. McBride, RI, Pilgrim
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P. Swetland, SRI, Haddam Neck
J. T. Shediosky, SRI, Millstone 1&2
T. Rebelowski, SRI, Millstone 3
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J. Akstulewica, LPM, NRR
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J. Sh::a, LPM, NRR
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Robert J. Bores, DRSS
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November 19, 1986
Docket No. 50-245,
50-336
A05929
Dr. Thomas E. Murley
Regional Administrator
Region 1
U.S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA
19406
References:
(1)
T.
E.
Murley Letter to J.
F. Opeka, dated
July 22, 1986, Inspection Report No.
50-245/86-06, 50-336/86-06 and 50-213/86-04.
(2)
J. F. Opeka Letter to T.
E. Murley, dated
August 21, 1986, Response to Inspection No.
50-245/86-06, 50-336/86-06 and 50-213/86-04.
Gentlemen
Millstone Nuclear Power Station, Units 1 and 2
Update to Response to I& E Inspection No. 50-245/86-06 and 50-336/86-04
Reference (1) informed Northeast Utilities of five Level IV
violations, which were identified during inspections at the
Millstone Nuclear Power Station (March 24-27, 1986).
In addition
to responding to the inspection report, Reference (1) directed
that an update be provided overy 90 days until all upgrades are
completed.
Reference (2) responded to Reference (1).
This report is the
first 90 day update.
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Alleged Violation:
10 CFR 71.5 requires that each licensee who transports licensed
material outside of the confines of its plant or other place of
use, or who delivoro licensed material to a carrier for tranc-
port, shall comply with the applicable requirements of the
regulations appropriate to the mode of transport of DOT in 49 CPR
Parts 170 through 189.
49 CFR 172.403(c) requires, in part, that a Radioactive
Yellow-III label must be affixed to each package of radioactive
material which measures in excess of 1.0 millirem at one meter
from each point on the external surface of the package.
In
addition, 49 CFR 172.504 requires that a vehicle transporting
packages of radioactive material must be placarded if the vehicle
contains packages of licensed material that are labeled
Radioactive Yellow-III.
Contrary to the above, on March 5,
1986, licensed material was
delivered to a carrier for transport in a package which had a
radiation level of 3.0 millirem per hour at 1 meter from the
surface of the package, and the package was erroneously labeled
Radioactive-Yellow II rather than Radioactive Yellow-III as
required.
As a result, the vehicle containing the package was
not placarded, as required by 49 CFR 172.504(a).
This is a Severity Level IV violation.
(Supplement V)
Response
Root Cause:
The individual (s) responsible for the preparation of
shipping papers and compliance with 49 CFR regulations were not
sufficiently trained in DOT regulations to properly label and
placard this shipment.
Corrective Steps Taken
Millstone Station has provided
additional training to individuals involved in the transport of
radioactive material.
Training sessions which were held are
listed on Attachment 1.
Corrective Steps to Avoid Future Violations:
Millstone Station
will develop and implement a continuing training program for
Radwaste personnel.
The Health Physics section of the Technical Training Branch of
the Nuclear Training Department will complete a job analysis and
procedure based task analysis in accordance with procedure
NTM-1.06, " Systematic Instructional Design" for the following
areas:
Radwaste Handlers, Radwaste Supervision and Station
Technician (R/W), and Radwaste OA/OC by February 28, 1987.
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A set of instructional objectives resulting from this analysis
effort will be produced and approved by the Training Program
Control Committee for Radwaste by March 30, 1987.
A performance based continuing training program consisting.
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of classroom and on-the-job training will be developed by July
30, 1987 and completely implemented prior to December 31, 1987.
Date When Full Compliance Will Be Achieved:
The continuing
training program will be established and attended by all Radwaste
personnel by December 31, 1987.
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90 Day Status
Training program is being developed and will be implemented by
December 31, 1987 as previously committed.
The NUSCO Training
Department will conduct a course on radioactive materials
shipping for all new Radioactive Materials Department personnel
as soon as practical following the hiring.
Alleged Violation:
10 CPR 50, Appendix B,
Criterion II requires, in part, that the
licensee shall provide for indoctrination and training of
personnel performing activities affecting quality as necessary to
assure that suitable proficiency is achieved and maintained.
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Contrary to the above, as of March 27, 1966, the Acting
Radioactive Materials Handling Supervisor and the principal
Radioactive Waste Materials Handler, who are involved in'an
activity affecting quality in the handling of radioactive
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materials, were not adequately trained to assure that suitable
proficiency was achieved and maintained.
Specifically, the
Acting Radioactive Materials Handling Supervisor had been in the
position for about a year and had not received any training in
the transportation of radioactive material.
The Radioactive
Waste Material Handler, who has been in his position for about a
year, received only 2-3 days training about a year ago, which was
insufficient to assure that suitable proficiency was achieved and
maintained in the area of transportation of radioactive material
in light of the complexity of these regulations and of the
complexity of the transportation activities at Millstone Nuclear
Power Station.
This is a Severity Level IV violation.
(Supplement V)
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Response:
Root Cause:
Adequate training was not made available to
individuals involved in the shipment of radioactive waste to
assure suitable proficiency was achieved and maintained as per 10 CFR 50.
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Corrective Steps Taken:
Millstone Station has provided
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additional training to individuals involved in the shipment of'
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radioactive waste to assure suitable proficiency l'in the area of
transportation of radioactive material.
See Attachment 1.
Corrective Steps to Avoid Future Violations:
Millstone Station
will develop and implement a continuing training program in
transportation of radioactive material to insure suitable
proficiency is maintained.
Date When Full Compliance Will Be Achieved:
The continuing
training program will be established and attended by all Radwaste
personnel by December 31, 1987.
90 Day Status
Training program is being developed and will be implemented by
December 31, 1987.
In the interim the Radiation Protection
Supervisor - Radioactive Materials has attended Chem' Nuclear's
" Workshop on Radioactive Waste Packaging, Transportation and
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Disposal" at Charleston, S.C.
This training was conducted on
October 21 thru 23, 1986.
Alleged Violation:
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10 CFR 71.12(a) permits a general license to be issued to any
licensee of the Commission to transport, 'or to deliver to a
carrier for transport, licensed material in a package for which a
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licensee, certificate of compliance, or other approval has been
issued by the NRC.
10 CFR 71.12(c) states that this general license applies only to
a licensee who has a copy of the specific license, certificate of
compliance, or other approval of the package, and has the
drawings and other documents referenced in the approval relating
to the use and maintenance of the packaging and to the actions to
be taken prior to shipment.
Contrary to the above, on March 5,
1986 and March 14, 1986, the
licensee delivered licensed material to a carrier for transport
to the Barnwell, S.C. burial Site in a package approved by the
NRC, and the licensee did not have the drawings and other
documents referenced in the approval relating to the use and
maintenance of this type of package.
This is a Severity Level IV violation.
(Supplement V)
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Responset
Root Cause:
At the time of the March 5,
1986 shipment, the
referenced documents were reviewed and available at Millstone
Station.
After the shipment was made, Chem Nuclear Systems
changed the status of the cask and requested return of all
company proprietary information including these documents.
Radwaste supervision was not aware of the 10 CFR 71.12 require-
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ments for long term retention of documents referenced in the
approval of the package.
At the time of the March 14, 1986
shipment, Radwaste supervision had not retained the referenced
drawings for this package.
Corrective. Steps Taken:
Radwaste supervision obtained copies of
all documents and drawings utilized in the preparation of the
radioactive shipments referenced above as required by 10 CFR 71.12.- : Shipment related documents and drawings required by 10 CFR 71.12 are currently being retained.
Corrective Steps To Avoid Future Violation:
Radioactive shipping
document and drawing retention as required by 10 CFR 71.12 will
be clarified in radwaste shipping procedures.
Date When Full Compliance Will Be " Achieved:
Radwaste procedures
will be revised to clarify document and drawing retention
requirements by December 31, 1986.
90 Day Status:
Procedures are being revised and will be approved by the Site
Operations Review Committee by December 31, 1986.
Procedures
affected include RW 6003/26003/36003 and RW 6004/26004/36004.
Alleged Violation:
Technical Specification 6.14, requires that the Solid Radioactive
Waste Treatment System used to process wet radioactive wastes
shall be operated in accordance with the Process Control Program
to ensure the processed waste meets shipping and burial ground
requirements.
Item 4,
" Commitments" of the Process Control
Program for the Millstone Nuclear Power Station requires that
approved station or vendor procedures will include the following
detailed information:
a.
A general description of laboratory mixing of a sample of the
waste to arrive at process parameters prior to commencing the
solidification process.
b.
A general description of the solidification process including
types of solidification agent, process control parameters,
parameter boundary conditions, proper waste form properties,
and assurance the solidification systems are operated within
established process parameters.
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c.
A general description of sampling of at least one
representative sample from every tenth batch to ensure
solidification and action to be taken if the sample fails to
verify solidification.
d.
Provisions to verify the absence of free liquid.
e.
Provisions to process containers in which free liquids are
detected.
f.
Specification of the process control parameters which must be
met prior to capping the container if the solidification is
exothermic.
Contrary to the above, between March, 1985 and March, 1986, a
contract vendor was used to solidify radioactive wastes *for
shipment to burial sites, and the vendor's procedures did not
include all of the detailed information required by Item 4 of the
Process Control Program in that only Item d. above was included
in the procedures.
This is a Severity Level IV violation.
(Supplement V)
Response:
Root Cause:
At the time of the solidification, no detailed
procedures were in ef fect which specified the information which
needs to be included in Station and Vendor solidification
procedures.
Corrective Steps:
A corporate procedure, NEO 6.07, " Quality
Assurance and Quality Control in Station Radioactive Material
Processing, Classification, Packaging, and Transportation" has
been implemented which contains these process control program
requirements.
A new Station Administrative Control Procedure,
"ACP-0A-2.01B, Quality Assurance and Quality Control in Station
Radioactive Material Processing Classification, Packaging and
Transportation", implements NEO 6.07 at Millstone Station.
Corrective Steps to Avoid Future Violations:
Existing Station
and Vendor procedures will be reviewed and upgraded as necessary
prior to use to ensure they comply with the process control
program requirements detailed in ACP-0A-2.01B, " Quality Assurance
and Quality Control in Station Radioactive Material Processing
Classification, Packaging and Transportation".
Date When Full Compliance Will Be Achieved:
All radioactive
waste solidification procedures will be reviewed and revised as
necessary to comply with ACP-0A-2.01B by December 31, 1986.
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90 Day Status
All Station and Vendor procedures being utilized at this time
have been reviewed and revised as necessary to ensure compliance.
This action is complete.
Alleged Violation:
10 CFR 20.311(d)(3) requires the conduct of a quality control
program to assure compliance with 10 CFR 61.56.
requires, in part, that waste must be structurally stable,
i.e.,
the waste will generally maintain its physical dimensions and
form under the expected disposal conditions.
The licensee
solidifies waste by means of its Process Control Program.
Contrary to the above, on March 14, 1986, the licensee shipped
4.1 curies of radioactive material solidified in cement and
packaged by a vendor to the Barnwell, S.C. burial site (Shipment
No. 86-009-1), and a quality control program to assure compliance
with 10.CFR 61.56 was not implemented in that the licensee did
not verify that the numerous requirements specified in the
Process Control Program had been satisfied to ensure that the
waste was structurally stable.
This is a Severity Level IV violation.
(Supplement V)
Response:
Root Cause :
No Corporate or Station procedures were in effect at
the time of solidification which addressed the process control
program required by 10 CPR 61.56.
Corrective Steps Taken:
A corporate policy has been implemented
which details a quality control program to assure compliance with
Corrective Steps Taken to Avoid Future Violations:
Two
procedures are now in effect which detail process control program
requirements for compliance with 10 CFR 61.56:
NEO 6.07, " Quality Assurance and Quality Control in Station
Radioactive Material Processing, Classification, Packaging
and Transportation".
Effective March 25, 1986.
ACP-QA-2.01B, " Quality Assurance and Quality control in
Station Radioactive Material Processing, Classification,
Packaging and Transportation".
Effective June 24, 1986.
All Vendor and Station radioactive waste solidification
procedures will be reviewed and revised prior to use to ensure
compliance with NEO 6.07 and ACP-0A-2.01B.
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Date When Full Compliance Will Be Achieved:
All Vendor and
Station procedures involving solidification of radioactive waste
will be in compliance with ACP-0A-2.01B by December 31, 1986.
90 Day Status
All Station and Vendor procedures being utilized at this time
have been reviewed and revised as necessary to ensure compliance.
This action is complete.
Improvements to Radioactive Material Shipping Department
In addition to the specific corrective actions taken, the
following improvements have been made to the radioactive
materials shipping program:
1.
A re-organization of the radioactive waste group has been
completed.
The following new positions have been created to
improve the management and preparation of radioactive
materials for shipment:
Radiation Protection Supervisor - Radioactive Materials
Assistant Radiation Protection Supervisor - Radioactive
Materials
Station Technician A
Radioactive Materials Handlers (7 positions)
The Radiation Protection Supervisor and Assistant Radiation
Protection Supervisor positions have been filled.
Job offers are being made to the seven personnel selected as
Radioactive Material Handlers.
Interviews are being
conducted for the Station Technician A position.
Staffing completion for the above positions is targeted for
December 31, 1986.
The Radiation Protection Supervisor - Radioactive Materials
will report to the Health Physics Supervisor.
2.
Additional training has been provided for individuals
involved in the shipment of radioactive materials.
(See
Attachment 1.)
In addition, a continuing training program
will be established and implemented in 1987 for individuals
involved in the preparation and shipment of radioactive
materials.
3.
The site OA/0C Department, through the use of OA surveillance
(activity observation) and inspections will monitor the
processing, packaging and shipping of radioactive waste.
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At least once per month, periodic surveillance of the
processing of radioactive waste including packaging and
shipping will be performed.
The packaging and shipping
aspects will also be covered via inspect!on and hold points
in the procedures and work orders.
These programs are
established, working and are conducted under the joint
Corporate / Site audit program.
Audits done during this period
are listed below with area inspected:
NNECO OA Surveillance
073086 - Spent Resin Processing
080786 - Safety Stand for LSA Box Inspection
100186 - Procedure Compliance
NUSCO OA Surveillance
092286-101086 - Radioactive Material Shipping Compliance
NUSCO Radiological Assessment Branch - Health Physics Audit
082086-082186 - Radioactive Processing, Waste Classifi-
cation, Area Posting, Radioactive
Material Control
4.
Additional programs for reducing the volume of radioactive
waste are being implemented.
A project assignment for
improved compaction equipment has also been initiated.
Super
compaction equipment and/or services supplied by Scientific
Ecology Group, Inc., Westinghouse and General Electric are
under evaluation.
A status report of upgrades and improvements in our program for
preparation, packaging and shipment of radioactive materials will
be furnished to you every 90 days until upgrades are completed.
Very truly yours,
NORTHEAST NUCLEAR ENERGY COMPANY
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Opekd
Senior Vice President