ML20211Q286

Ack Receipt of in Response to Requests for Updates on Program Improvement Plan for Radwaste Preparation,Packaging & Shipping,Re Combined Insp Repts 50-245/86-06,50-336/86-06 & 50-213/86-04

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 ,

50-213

Northeast Nuclear Energy Company

ATTN: Mr. J. F. Opeka

Senior Vice President - Nuclear '

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

v 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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l P. Swetland, SRI, Haddam Neck

J. T. Shediosky, SRI, Millstone 1&2

T. Rebelowski, SRI, Millstone 3

, J. Akstulewica, LPM, NRR

! J. Sh::a, LPM, NRR

i D. Osborne, LPM, NRR

Robert J. Bores, DRSS

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(203) 665-5000

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. _

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. <

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

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assure that suitable proficiency is achieved and maintained.

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. '

Corrective Steps Taken: Millstone Station has provided ..

additional training to individuals involved in the shipment of' .

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 -

Disposal" at Charleston, S.C. This training was conducted on

October 21 thru 23, 1986.

Alleged Violation: '

10 CFR 71.12(a) permits a general license i 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 ,

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. 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

10 CFR 61.56.

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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NFJ/ F. Opekd

Senior Vice President