ML20212A154

Notice of Violation from Insp on 860324-27.Violation Noted: on 860305,licensed Matl Delivered to Carrier for Transport in Package W/Radiation Level of 3.0 M/H at 1 Meter from Surface

ML20212A154
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	07/22/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212A139	List: ML20212A135 ML20212A154 ML20212A174
References
50-245-86-06, 50-245-86-6, 50-336-86-06, 50-336-86-6, EA-86-117, NUDOCS 8607280127
Download: ML20212A154 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Northeast Nuclear Energy Company Docket Nos. 50-245 Millstone Nuclear Power Station, Units 1 and 2 50-336 License Nos. DPR-21 DPR-65 EA 86-117 During an NRC inspection conducted on March 24-27, 1986, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C, (Enforcement Policy) (1986), the violations are set forth below:

A. 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 delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR 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 labelled 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 labelled Radioactive-Yellow II rather than Radio-active 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)

B. 10 CFR 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 profi-ciency is achieved and maintained.

Contrary to the above, as of March 27, 1986, 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 materials, were not adequately trained to

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2 Enclosure 1 assure that suitable proficiency was achieved and maintained. Specifi-cally, 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)

C. 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 license, certificate of compli-ance, 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 compli-ance, 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 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)

D. 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, " Commit-ments" 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 solidifica-tion 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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3 Enclosure 1

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)

E. 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. i This is a Severity Level IV violation. (Supplement V)

Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the reas as for the violations, if admitted; (2) the corrective steps which have been taken and the results achieved; (3) corrective steps which will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.

Dated at King of Prussia, Pennsylvania this,J) ay of July 1986

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