ML20215J662
| ML20215J662 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 09/08/1986 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8610270138 | |
| Download: ML20215J662 (2) | |
See also: IR 05000213/1986004
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SEP Oe1995
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Docket Nos. 50-213
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50-245
50-336
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Northeast Nuclear Energy Company
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ATTN: Mr. J. F. Opeka
Senior Vice President - Nuclear
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Engineering and Operations Group
P. O. Box 270
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Hartford, Connecticut 06141-0270
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Gentlemen:
Subject: Combined Inspection Nos. 50-213/86-06, 50-245/86-06 and 50-336/86-06
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This refers to your letter dated August 21, 1986, in response to our letter
dated May 30, 1986.
Thank you for informing us of the corrective and preventive act{pns documented
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in your letter. These actions will be examined during a future inspection of
your licensed program.
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Your cooperation with us is appreciated.
Sincerely,
Original Sicned B 1
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omas T. Martin, Directdf
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D v sion of Radiation Safety
and Safeguards
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cc:
E. J. Mroczka, Vice President, Nuclear Operations
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W. D. Romberg, Station Superintendent
D. O. Nordquist, Manager of Quality Assurance
R. T. Laudenat, Manager, Generation Facilities Licensing
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Gerald Garfield, Esquire
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R. Graves, Plant Superintendent
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
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Stata of Connecticut
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0FFICIAL RECORD COPY
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Northeast Nuclear Energy Company
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief
M. McBride, RI, Pilgrim
P. Swetland, SRI, Haddam Neck
J. T. Shediosky, SRI, Millstone 3
J. Shea, LPM, NRR
Robert J. Bores, DRSS
T. Rebelowski, SRI, Millstone 1&2
J. Akstulewicz, LPM, NRR
D. Osborne, LPM, NRR
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NORTHEAST UTILITIES
cenerei orrices seicen street. Beriin. connecticut
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P.o. BOX 270
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HARTFORD. CONNECTICUT 06141-0270
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August 21, 1986
Ibcket Nos. 50-213
50-245
50-336
A05929
D . 'Ihmas E. Murley
Regional Administrator
Region 1
U.S. Nuclear Regulatory Ccmnission
631 Park Avenue
King of Prussia, PA 19406
Reference: (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.
Gentimen:
Haddam Neck Plant
Millstone Nuclear Power Station, Units 1 and 2
Response to I&E Inspection No. 50-245/86-06, 50-336/86-06 and 50-213/86-04
Pursuant to the Provisions of Section 2.201 (" Notice of Violation")
and Appendix C (Enforement Policy) of the NRC's Rules of Practice (10 CFR 2), this report is submitted in reply to reference (1).
Reference (1) informed Northeast Utilities of eight Invel IV
violations, which were identified during inspections at the Haddam
Neck Plant (March 10-14, 1986) and at the Millstone Nuclear Power
Station (March 24-27, 1986).
Millstone:
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 delivers licensed material to a carrier for transport, shall
emply with the applicable requirements of the regulations appropriate
to the mode of transport of DDT in 49 CFR Parts 170 through 189.
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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
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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 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).
Restonse:
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Ibot Cause: The individual (s) responsible for the preparation of
shipping papers and cmpliance with 49CFR regulations were not
sufficiently trained in DDT regulations to properly label and placard
this shipnent.
Corrective Step 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 implenent 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 NIM-1.06, " Systematic
Instructional Design" for the following areas: Radwaste Handlers,
Radwaste Supervision and Station Ibchnician (R/W), and Radwaste ON/0C
by February 28, 1987.
A set of instructional objectives resulting from this analysis effort
will be produced and approved by the Training Program Control
Ccmnittee for Radwaste by March 30, 1987.
A performance based continuing training program consisting of
classroam and on-the-job training will be developed by July 30, 1987
and conpletely implemented prior to December 31, 1987.
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Date When Full Compliance Will Be Achieved: The continuing training
program will be established and attended by all Radwaste personnel by
D3cember 31, 1987.
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Alleged Violation:
10 CFR 50, Appendix B, Criterion II requires, in part, that the
licensee shall provide for indoctrination and training of personnel
perfoming activities affecting quality-as necessary to assure that
suitable proficiency 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 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 Radio-
active 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 emplexity of these regulations and of the cmplexity of
the transportation activities at Millstone Nuclear Power Station.
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This is a Severity Level IV violation.
(Supplement V)
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 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.
[hte When Full Cbmpliance Will Be Achieved: The continuing training
program will be established and attended by all Radwaste personnel by
December 31, 1987.
Alleged Violation:
10 CFR 71.12(a) pemits a general license to be issued to any licensee
of the Conmission to transport, or to deliver to a carrrier for
transport, licensed material in a package for which a license,
certificate of empliance, or other approval has been issued by the
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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
cmpliance, 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 doc m ents referenced in
the approval relating to the use and maintenance of this type of
package.
'Ihis is a Severity Level IV violation.
(Supplement V)
Response:
Root Cause: At the time of the March 5,1986 shipnent, the referenced
documents were reviewed and available at Millstone Station. After the
shipnent was made, Chem Nuclear Systems changed the status of the cask
and requested return of all cmpany proprietary infonnation including
these documents. Radwaste supervision was not aware of the 10 CFR 71.12 requirements for long tenn retention of doctraents 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.
Cbrrective Steps Taken: Radwaste supervision obtained copies of all
documents and drawings utilized in the preparation of the radioactive
shipnents referenced above as required by 10 CFR 71.12.
Shipment
related documents and drawirgs 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 CPR 71.12 will be
clarified in radwaste shipping procedures.
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Date When Full Ccmpliance Will Be Achieved: Radwaste procedures will
be revised to clarify document and drawing retention requirements by
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December 31, 1986.
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Alleged Violation:
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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
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4, "Ccunitments" of the Process Control Program For the Millstone
Nuclear Power Station requires that approved station or vendor
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procedures will include the following detailed information:
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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 incitiding
types of solidification agent, process control parameters,
parameter boundary conditions, proper waste form properties, and
assurance the solidification systens are operated within
established process parameters.
c.
A general description of sampling of at least one representative
sample fram 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.
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Provisions to process containers in which free liquids are
detected.
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Specification of the process control parameters which must be met
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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 solidfy radioactive wastes for shipnent to burial
sites, and the vendor's procedures did not include all of the detailed
information required by Itan 4 of the Process Control Program in that
only Item d. above was included in the procedures.
'Ihis is a Severity level IV violation.
(Supplement V)
Response:
Root Cause: At the time of the solidification, no detailed procedures
were in effect which specified the information which needs to be
~ included in Station and vendor solidification procedures.
Corrective Steps: A corporate procedure, "NED 6.07, Quality Assurance
and Quality Control in Station Radioactive Material Processing,
Classification, Packaging, and Transportation" has been implemented
which coritains these process control program requirements. A new
Station Administrative Control Procedure, "ACP@-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 canply with the process control program require-
ments detailed in ACP-CA-2.01B, " Quality Assurance and Quality Control
in Station Radioactive Material Processing Classification, Packaging
and Transportation".
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Ehte When Full Cmpliance Will Be Achieved: All radioactive waste
solidification procedures will be reviewed and revised as necessary to
cmply with ACP@-2.01B by December 31, 1986.
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Alleged Violation:
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10 CFR 20.311(d)(3) requires the conduct of a quality control program
to assure cmpliance 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 Progran.
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 (Shipnent No. 86-009-1), and
a quality control program to assure cmpliance 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
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satisfied to ensure that the waste was structurally stable.
This is a Severity Ievel IV violation.
(supplanent 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 CFR 61.56.
Corrective Steps Taken: A corporate policy has been implemented which
details a quality control program to assure cmpliance 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
empliance 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 @ -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
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will be reviewed and revised prior to use to ensure compliance with
NDO 6.07 and ACP-OA-2.01B.
Date When Full Cmpliance Will Be Achieved: All Vendor and Station
Procedures involving solidification of radioactive waste will be in
cmpliance with ACP@-2.018 by Ibcember 31, 1986.
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In addition to the specific corrective actions taken in response to
the violations noted in this inspection, the following improvements
have been made to the radioactive materials shipping program:
1.
A re-organization of the radioactivs waste group has been
conpleted. We following new positions have been created to
improve the management and preparation of radioactive materials
for shipnent:
Radiation Protection Supervisor - Radioactive Materials
Assistant Radiation Protection Supervisor (Ralioactive
Materials)
Station Technician A
Radioactive Materials Handlers (7 positions)
Staffing conpletion for the above positions is targeted for
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December 31, 1986.
he Radiation Protection Supervisor - Radioactive Materials will
report to the Health Physics Supervisor.
2.
Additional training has been provided for individuals involved in
the shipnent 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 shipnent of radioactive materials.
3.
We sitc OA/0C Department, through the use of OA surveillance
(activity observation) and inspections will mnitor the
processing, packaging and shipping of radioactive waste.
At least once per mnth, periodic surveillance of the processing
of radioactive waste including packaging and shipping will be
performed. W e packaging and shipping aspects will also be
covered via inspection and hold points in the procedures and work
orders. W ese programs are established, working and are conducted
under the joint Corporate / Site audit program.
4.
Additional program for reducing the volume of radioactive waste
are being implemented. A project assignment for imprm ed
compaction equipnent has also been initiated.
A status report of upgrades and improvanents in our program for
preparation, packaging and shipnent of radioactive materials will be
furnished to you every 90 days until the upgrades are conpleted.
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Haddan Neck:
Alleged Violation:
10 CFR 50, Appendix B, Criterion V requires, in part, that ac'tivities
affecting quality shall be prescribed by procedures which include
appropriate quantitative or qualitative acceptance criteria for
detennining that important activities have been ~ satisfactorily
acconplished.
Contrary to the above, prior to March 14, 1986, an activity affecting
the quality of radioactive waste disposal, namely, verification of the
identity and activity of radionuclides in radioactive waste shipnents,
was perfonned using procedures which did not provide appropriate
quantitative or qualitative acceptance criteria for verifications of
the identity and activity of radionuclides in radioactive waste
shipnents. Specifically, the procedures did not provide criteria for
the verification of the identity and curie content of certain
nuclides.
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Response:
Training programs were conducted for all ON/0C inspectors involved
with radioactive waste materials. Also all radwaste technicians were
retrained on the various aspects of their job requirements. Radwaste
handling procedures were revised to incorporate " hold points".
Procedure work sheets were implemented to include all significant
identified isotopes along with the criteria for verification. An
independent reviewer now reviews shipping documents to ensure
conpliance with this requirement.
%ese actions were completed by June 13, 1986.
Alleged Violation:
10 CFR 20.311(b) requires, in part, that each shipnent of radioactive
waste to a licensed land disposal facility must be acconpanied by a
shipping manifest which indicates as conpletely as practicable the
radionuclide identity and quantity and the total radioactivity of the
shipnent.
10 CPR 20.311(c) requires, in part, that the manifest must
include a certification by the waste generator that the transported
mterials are properly described.
Contrary to the above, between February 20, 1985 and March 13, 1986,
18 shipnents of radioactive waste, which contained several radio-
nuclides including Iron-55, were sent to a burial site and were
acconpanied by manifests which did not identify the existence and
quantity of the radionuclide Iron-55 in the shipnent. As a result,
the total radioactivity stated on the manifests was in error. We
numbers of the shipnents were W-85-1, W-85-2, W-85-3, W-85-5, W-85-8,
W-85-9, W-85-10, W-85-11, W-85-12, W-85-13, W-85-15, W-85-18, W-85-19,
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W-86-5, W-86-6, W-86-8, W-86-9 and W-86-11.
Further, the certifi-
cations which acconpanied the manifests were also in error.
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Response:
A letter was sent to Mr. J. Still, Regulatory Affairs, Olem N clear
Systens, Barnwell, S.C. and also to Virgil R. Autry, Director,
Division of Radioactive Material Licensing and Compliance, State of
South Carolina. This letter updated our shipment activity totals for
1984, 1985 and 1986.
Procedure RAP 6.3-5 " Radioactive Material Management" has been revised
to require an independent reviewer to evaluate shipping documents to
verify that waste shipnents are properly described.
Alleged Violation:
10 CFR 71.5(a)(1)(vi) requires that shipping papers be prepared in
accordance with 49 CFR 172, Subpart C.
49 CFR 172.203(d)(i) requires
the name of each radionuclide in the shipr.ent and 49 CFR 172.203(d)
(iii) requires the activity of each package in the shipnent be
included in the shipping papers.
Contrary to the above, between February 20, 1985 and March 13, 1986,
18 shipnents of radioactive waste which contained several radio-
nuclides including Iron-55, were sent to a burial site and the
shipping papers did not include the identity of Iron-55 in the
shipments and the activity resulting fran that radionuclide.
Response
Procedure RAP 6.3-5 " Radioactive Material Management" was revised to
include Iron-55 as an iten of the radwaste worksheet. This will
ensure the proper radionuclides will be included on the shipping
manifests and the independent reviev ensures that verification of
shipping documents are properly described.
Very truly yours,
NORIBEAST NUCLFAR ENERGY COMPANY
CONNECfICUr YANKEE ATOMIC POER COMPANY
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Opeka
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Se i r Vice President
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By:
R. PT Werner
Vice President
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Attachment
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Attachment 1
Radwaste Training Conducted /A_ttending as of 8/1/86 ~
Title
Intes
(1) NUS training session for Radwaste Handlers
03/31/86 - 04/01/86
(2) NUS training session for Radioactive Materials
04/02/86 - 04/04/86
Supervision, Shippers and QA/QC Inspectors
(3) NUSCo Training Department course of radioactive 07/14/86 - 07/18/86
materials shipping
07/21/86 - 07/25/86
(4) CNSI hbrkshop on Radioactive Wste Packaging,
05/28/86 - 05/30/86
Transportation and Disposal - attended by
Radioactive Materials Handling Supervisor
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