W3P88-1919, Responds to Violations Noted in Insp Rept 50-382/88-20 Re transportation-related Violations Issued by State of Nv Against Low Level Radioactive Waste Shipments.Corrective Actions:Procedural Revs & Review of Violations
| ML20155G107 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/10/1988 |
| From: | Burski R LOUISIANA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| W3P88-1919, NUDOCS 8810140080 | |
| Download: ML20155G107 (27) | |
Text
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s n LOUISI&AN POWER A/
LIGHT 317 BARONNESTREET NEW P. O. BOX 60340 ORLEANS, LOUISIANA 70160 *
(504) 595 3100 Uf N IIrsit October 10, 1988 W3P88-1919 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
SUBJECT:
Waterford Steam Electric Station - Unit Number 3 Docket Number 50-382 NRC Inspection Report 88-20 Gentlemen:
The subject Inspection Report identified unresolved item 8820-02 regarding transportation-related violations issued by the State of Nevada against los level radioactive waste shipments from Waterford 3 to the Beatty, Nevada disposal site. Messrs. D. Chaney and R. Baer, NRC Region IV, requested a letter summarizing the otatus of these violations during a conference call on Septeober 9, 1988. This letter responds to their request.
Low level radioactive waste shipment numbers 88-1008 and 88-1009 arrived at the disposal site on May 31, 1988 and June 3, 1988, respectively; 88-1010 and 88-1011 both arrived on June 6, 1988. These shipments all arrived within a one week period and are the shipments for which violations were issued. The violations can be summerized as fol'.ows:
- 1. Manifests accompanying shipment numbers 88-1008, 1009, and 1011 each had an illegible copy attached;
- 2. One of the placards on the front of the vehicle transporting s_hipment number 88-1008 was improperly displayed; and
- 3. Shipment number 88-1010 appeared to have shifted slightly during transport and a small hole was found on *he front of one of the packages in the shipment.
Another violation had been issued against s,hipment number 88-1010, citing discrepancies between package dosa rates indicated on the manifest and those measu*ed at the disposal site. This violation was rescinded, however, after Louisiana Power & Light Company (LF6L) contactri the disposal site Radiation Safety Officer and demonstrated that the violation could not have been issued against LP6L's shipment.
8810140080 OUJ010 gDR ADOCK 05000302 PNU "AN EQUAL OPPORTUNITY EMPLOYER"
', 5 Page 2 W3P88-1919 October 10, 1988 LP&L instituted corrective actions, including procedural revisions and review of the violations, regulatory requirements and procedural revisions with personnel involved with radioactive waste shipments in response to these violations. These actions were detailed in letters to the State of Nevada dated July 5, 1988, July 25, 1988, and August 4, 1988. The State of Nevada acknowledged LP&L's corrective actions in letters dated July 12, 1988, August 1, 1988, and August 12, 1988; and provided clarification that LP&L could resume shipments to Beatty in a letter dated September 19, 1988.
LP&L feels that it has appropriately addressed these violations, and based on correspondence from the State of Nevada, considers these violations closed.
Messrs. Chaney and Baer indicated during the aforementioned conference call i that unresolved item 6820-02 could be closed based on documentation of resolution by the State of Nevada. Copies of ell correspondence referenced in this letter, plus the letter rescinding the dose rate violation, and the lettern citing the violations are attached for your review. These attachments comprise a complete package of all correspondence related to the violations and document the fact that this issue has been resolved with the State of Nevada, pending inspections of future shipments to Beatty to verify that the corrective actions have been effective. LPSL therefore requests that unresolved item 8820-02 be closed.
Specifics of the violations and corrective actions have not been reiterated in this letter as the information is fairly detailed and clearly presented in the attached correspondence. Should you wish to discuss this matter further or require additional information, please contact Chadi D. Groome at (504) 595-2846.
Yo rs very truly.
[ pc.w R.,[ Burshi M< ager Nuclear Safety & Regulatory Affairs RFB:CDC ssf Attachments cc: E.L. Blake, W.M. Stevenson, J.A. Calvo, D.L. Vigginton, R.D. Martin, NRC Resident Inspector's Office (W3)
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- List of Attached Correspondence State of Nevada to LP&L - 8 letters dated:
June 7, 1988 June 30, 1988 (3 letters)
July 12, 1988 August 1, 1988 August 12, 1988 September 19, 1988 LP&L to State of Nevada - 3 letters dated:
July 5, 1988 July 25, 1988 August 4, 1988
\ 6 fQ. l CICri4RD H. BRYAN STATE oF. NEVADA 1.A% H EM.E. P M tf Hil% Go.ernir - Adm1metrator JERRY GRaiPENTROG JOSEPH Q JARVI5. M D. Diretter Hearth Officer j i **J DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Radiological Health Section 505 East King Strees. Room 203 Carson City, Nevada 89710 (702) 8854394 June 7, 1988 J.M. Cain Louisiana Power and Light Company 317 Baronne Street New Orleans, LA 70160
Dear Mr. Cain:
This letter is in reference to Louisiana Power and Light Company LLW shipment no. 88-1008 which arrived at the Beatty, NV disposal site on May 31, 1988 under Nevada Site User Permit No. Q446. Inspection findings revealed the following violations:
- 1. OOl -Q4 4 6 1 U.S. Department of Transportation regulation 49 CFR 172.516(c)(4) requires each placard to be located away from any marking, such as advertising, that could substantially reduce its effectiveness, and in any case, at least 3 inches (76.0 mm.) away from such markings.
Contrary to this requirement, the placard located on the front of the transport vehicle was located within three (3) inches of a license plate holder which was displaying four license plates. The top of the placard was also wrapped over the top of the vehicle bumper which should be prevented on future shipments. The entire placard must remain compictely visible.
- 2. 001-Q446-4-2
- 49. CFR 172.201(a)(2) states that the required shipping description on a shipping paper and all copies thereof use for transportation purposes, must be lagible and printed (manually or meet.anically ) in English.
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,1 Contrary to this requirement, the carrier copy of the shipping manifest furnished with the shipment had several portions which were'not clearly legible. The violation appears to be a result of an improper printer font or inadequate pressure on the printer.
r I You are required to advise this office in writing within 20 days of your receipt of this letter to indicate the actions that will be taken to correct these vielations, when the corrective actions will be implemented and the methods that will be taken to prevent recurrence of the violations. Sincerely, 1
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Stani R. Marshall, Supervicor Radiological Health Section Bureau of Regulatory Health Services Enclosure llw\lplevioltr . cc: Bill Spell, State of Louisiane Virgil Autry, State of South Carolina . Earl Ingersoll, State of Washington L.,s, / .^ : . ' Jack Hornor, Region V, NRC Bert Gray, Nevada Health Division 4 / r J l l t n ,,-.- , y .,.g ,--.--,---we-.- ---,-----,--,-,n,--- ,--,,-an,,,-wn,. - , - - - .,,,,..m.,, -.----,,,-,g- _,-nw-
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RICHARD H BRYAN STATE OF NLVADA L 4%RENCE P MATHt!> Gossenor A d m enes '*eoor Jf!RY GRitPENTROG JOSEe'H Q JARkl5 MD insetter 3, Heelsh Offeter I DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Radiologicie Health Section 505 East King Street. Room 203 Carson City, Nevada 89710 L (702) 885 5394 June 30, 1988 J. M. Cain Louisiana Power and Light Company 317 Baronne Street New-Orleanc, LA '70160 RE: 003-0446-2-1 003-Q446-3-1 003-Q446-3-2 -
Dear Mr. Cain:
This letter is in reference to the Louisiana Power and Light Company LLW shipment number 88-1010 which arrived at the Beatty site on June 6, 1988. The shipment was made under Nevada Site User Permit No. Q446 issued to Louisiana Power and Light Company, Waterford 3 SES. Inspection findings revealed the following violations:
- 1. 003-Q446-2-1 U.S. Department of Transportation regulation 49 CFR 173.425(b)(1) requires materials to be packaged in strong, tight packages so that there will be no leakage or radioactive material under conditions normally incident to transportation.
Contrary to this requirement, package number 88-0111 was found to have a hole in the front of the package. The hole was approximately 1/4 inch in diameter and was located 20 inches from the left side and 20 inches from the bottom of the package. No , loss of container contents was found as a result of the hole in the package.
- 2. 003-Q446-3-1 JUL g198?
49 CFR 173.425(b)(6) requires the shipment to be braced so as to prevent shitting of lading under conditions normally incident to transportation. 49 CFR 173.448(a) requires each shipment of radioactive material to be secured in order to prevent shifting during normal transportation conditions. Contrary to tnese requirements, the containers were found to have shifted to the front of the trailer as a result of the wooden wedges being released from between the containers curing transit. The release of the wedges created approximately 6 inches of space I between the rear floor bracing materials and the rear packages.
- 3. 003-Q446-3-2 Nevada Administrative Code 459.823(2) requires the manifest to l contain a statement which is as complete as is practicable and includes a physical description of the waste, its volume, the I identity and quantity of radionuclides, the total '
radioactivity and the principal chemical form. Contrary to this requirement, three packages were found to . have external radiation levels significantly different than the radiation levels indicated on the shipping manif est. The three packages, the indicated levels and measured radiation levels are as follows: package No. Indicated rad. level Measured rad. level 0111 800.0 mR/hr 550.0 mR/hr 0049 60.0 mR/hr 100.0 mR/hr l 0047 80.0 mR/hr 110.0 mR/hr l Mr. Larry Simon from your company was present during confirmation of the findings above. You are required to advise this office in writing within l 20 days of your receipt of this letter of the actions that will l be taken to correct the violations, when the corrective l actions will be implemented and the methods that will be used to prevent recurrence of the violations. Upon receipt of the corrective actions, we will review the response and advise you concerning resuming shipments to the Beatty site.
.o . -If you have any questions, please feel 1:eee to contact me.
Sincarely, . Sta hflaisE y R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services lw2\lplcitr cc: Bert Gray, Nevada Health Division Virgil Autry, State of South Carolina Earl Ingersoll, State of Washistgton Jack Hornor, Region V, NRC Bill Spell, State of Louisiana Novelle Tucker, U.S. DOT o b r l l
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JERRY GRlEPENTCOG JOSEPH Q JARV15. M D. Direeser , _ Heelt.% officer DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Radiological Health Secolon 505 East King Street Room 203 Carson City. Nevada 89710 (702) 885 5394 June 30, 1988 J. M. Cain T.ouisiana Power and Light Company 317 Baronne Street New Orleans, LA 70160 RE: 002-Q446-4-2 . Dear Mr. Caint - This letter is in reference to the Louisiana Power and Light Company LLW shipment number 88-1009 which arrived at the Beatty site on June 3, 1988. The shipment had been made under Nevada Site User Permit No. Q446 issued to Louisiana Power and Light Company, Waterford 3 SES. Inspection findings revealed the following violation:
- 1. 002-Q446-4-2 U.S. Department of Transportation reg;1ation 49 CFR 172.201(a)(2) requires the shipping description on a shipping paper and all copies thereof used for transportation purposes, to be legible and printed (manually or mechanically) in English.
Contrary to this requirement, the carrier copy of the shipping manifest fuzgished with the Louisiana Power and Light company shipment n q 88-1009 was not legible. This appears to have been caused gr the printing style of the manifest printer. You are requMred- to advise this office within 20 days of your receipt of this letter of the actions that will be taken to correct the violation, when the corrective actions will be implemented and the methods to prevent recurrence of the violation.
If you have any questions, please feel free to contact me. Sincerely, Sta Wey R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services lw2\lplevioltr cc: Bert Gray, Nevada Health Division Jack Hornor, Region V, NRC Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Bill Spell, State of Louisiana Novelle, Tucker, U.S. DOT l l l l l l 1 ) y. ( a..
flh) h Wst L" CICH A*.D H. BRYAN STATE OF NEVADA LA%RENCE P HfHEl% o.. .r u .........e JERRY GRIEPENTZOG JOSEPH Q JARtl5. M D Deretter 3' , Hentth Officer i DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Radiological Health Section 505 East King Street Room 203 Carson City. Nevada 89710 (702) 885 5394 June 30, 1988 J. M. Cain Louisiana Power and Light Company 317 Baronne Street New orleans, LA ,70160 RE: 004-Q446-4-3
Dear Mr. Cain ,
This letter is in reference to the Louisiana Power and Light Company LLW shipment number 88-1011 which arrive at the Beatty site on June 6, 1988. The shipment had been made under Nevada Sito User Permit No. Q446 issued to Louisiana Power and Light Company, Waterford 3 SES. Inspection findings revealed the following violation:
- 1. U.S. Department of Transportation regulation 49 CFR 172.201(s)(2) requires the shipping description on a shipping paper and all copies thereof used for transportation purposes, to be legible and printed (manually or me.:hanically) in English.
Contrary to this requirement, the carrier copy of the manifest could not be read. This appears to have been caused by the printing style of the manifest printer, you are required to advise this office within 20 days of your receipt of this letter of the actions that will be taken to correct the violation, when the corrective actions will be implemented and the methods to prevent recurrence of the violation. in erely, e , a y R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services JUL 6 1988
lw2\1plcio21tr , cc: Bert Gray, Nevada Health Division Jack Hornor, Region V, NRC ; Virgil Autry, State cf South Carolina Earl Ingersoll, State of Washington Bill Spell, State of Louisiana Novelle Tucker, U.S. DOT e I S h
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JETIY GT,ilPE*1TROG logtpH q igggg, yn Dars t ter ,. n ,,,, s o n,,,, g. DEPARTMENT OF HUMAN RESOURCES HEALTH Dit'IslO*e Radiolog6 cal Health Section SC Ea ,t King Street. Room 203 arson City, Nevada 19710 (702) 885 5394 July 12, 1988 R. F. Burski, Manager Nuclear Safety and Regulatory Affairs Louisiana Power and Light Company 0.0. Box 60340 Mail Unit N-17 New Orlearts. LA '70160
Dear Mr. Burski:
Your letter dated July 5, 1988 is acknowledged. The letter describes the actions that have been taken to correct the violations documented during our recent inspection of Louisiana Power and Light Company LLW shipment number 88-1008. The corrective actions will be reviewed during future inspections. You are requested to respond to the violation letters concerning shipment numbers 88-1009, 88-1010 and 88-1011 prior to resuming shipments to the Beatty site. If you have any questions, please feel free to contact this office.
'h etely, r%
t iJ3y R. ' Marshall, Supervisor Racio 1gical Health Seetion Bureau of negulatory Laith Servicts cc: Bert Gray, Nevada Health Division Bill Spell, State of Louisiana Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Jack Hernor, Region V, NRC Novelle Tucker, U.S. Dept. of Transportation
,, SEP-15 '80 12:18 I0: Ta. T: ::m n -
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"""' $5#7"G g ,9, bL DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION n.a.i.e. a Hestin s si 505 East Klas Street, Roota 203 '.,
Carson 'Aty, Nevede s9710 August 1, 1988 i700 ses sst4 R. F. Durski, Manager Nuclear Safety and Regulatory Affairs Louisiana Power & Light 317 Baronne Street New Orleans, LA 70160 - RE: 002-0446'-4-2 004-0446-4-3 Dear Mr. Burski Your letter dated July 25, 1988 is acknowledged. The letter describes the actions-that have been or-will be taken to correct the violations documented during recent inspections of LLW shipments from Louisiana Power & Light. The corrective actions will be reviewed during future inspections to determine their effectiveness. We are still awaiting a response to our letter dated June 30, 1988 concerning your LLW shipment number 88-1010. Upon receipt of the response, we will consider rein,.;tatement of permission to ship to the Beatty site. If you have any questions, please feel froo to contact me.
,incerely, l
hlalhYb y R. Marshall, Supervisor Radiological Health section Bureau of Regulatory Health Services i Iw2\1p101txt cr:: Bert Gray, Nevadt Health Division . Jack Hornor, Region V, NRC ' Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Bill Spell, State of Louisiana Novelle Tucker, U.S. Dept. of Tran::portation SEP 15 '88 14: 16 PAGE.002 s
%* Rid *H AID H 8;Y4N S14TE OF NEtAD A cz ,x .,
LAWRENCE P w it H t:5 u . . . . . . n e, t JERRY GIIEPENflOO . JOSEPH Q J A.% I % . 4 D 9 Onret ter
, Heelsh Offteer l l
l DEPARTMENT OF HUMAN RESOURCES HEALTH DIVISION Rameleccal Health Section 505 East King Street Room 203 Carson City Nevada 89710 (702) 885 5394 August 12, 1988 R. F. Burski, Manager Nuclear Safety & Regulatory Affairs Louisiana Power & Light 317 Baronne Street New Orleans, LA 70160 RE: 003-Q446-2-1, 003-Q446-3-1 Dear Mr. Burski Yc letter dated August 4, 1988 is acknowledged. The letter de ibed actions that will be taken to correct the violations doc ented during the recent inspection of LLW chipment no. 88-1010 from Louisiana Power & Light. The corrective actions were in response to violation numbers 003-Q446-2-1 and 003-Q446-3-1 cited in our letter dated June 30, 1988. The corrective actions will be reviewed during future inspections to determine their offectiveness. If you have any questions, please feel free 'o
. contact me.
Sincerely, 4 VLs Oc.k
- a ? v shall, Supervisor Radiolog.s,i salth Section Bureau of R.gulatory Health Services lw2\lpivioltr cc: Bert Gray, Nevada Health Division Earl Ingersoll, State of Washington Virgil Autry, State of South Carolina Novelle Tucker, U.S. Dept. of Transportation Bill Soell, State of Louisiana I
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SEP-20 '00 10:02 ID: TEL to uOS' Fei (* .. a1CHAAD C. maYAM STATE OF NF.VADA , o t.A'.?RINCE P. WAtHtts um, Juey sertMa00 Joln . JAR IS. 4 D. RECEIVED
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ses r uwe su t n.. aos Carsee Gip. Nevede s971o W ~ * (702) 845 5294 September 19, 1988 Chadi oroome Louisiana Power and Light Company P.O. Box 60340 Mail Unit N-17 New Orleans, LA 70160 Dear Ms. Groomon i This letter is in response to the request from your management concerning Permit No. LLW shipments to the Beatty, Ny site under Nevada Site User Q446 issued to Louisiana Power and Light company. Your letters dated July 5, 1988, July 25, 1988 and August 4, 1988 to this office shipments described to the the corrective actions for recent LLW Beatty site, cur letters dated July 12, 1988, August 12 and August 13,1988 advised that the corrective actions would be reviewad during future inspections of shipments from Louisiana Power and Light company. I regret that our review of the corrective sctions and acknowledgents in writing were not interpreted by your uanagement to include permissio.- to resume shipments to the M atty site. You are advised that Louisiana Power and Light Company is perraitted to ' resume LLW shipments to the Beatty site. 4 i i om st* 20 '88 12:01
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(. .. o If you have any further questions, please feel free to contact me. Sincerely,
?
Stan f R. Marshall, Supervisor Radiological Health section Bureau of Regulatory Health Services 3w2\lpigrmeltr cci Bert Gray, Nevada Health Division Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Bill spell, state of Louisiana SEP 20 '88 12:01 PAGE 002
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& TIGHT A / air NEW aiaoNNe $ raser 0%EANS. LOUISI AN A 70160 e (504) $95 3100 UrE3 d Msial July 5, 1988 W3P88-1631 A4.06 QA Mr. Stanley R. Marshall Department of Human Resources Health Division Radiological Health Section 505 East King Street, Room 203 Carson City, Nevada 98710
SUBJECT:
Waterford Steam Electric Statio'. - Unit Number 3 Nevada Radioactive Waste Dispos.1 Site User's Permit . Number Q446 Low Level Waste Shipment Number 88-1008
REFERENCE:
Department of Human Resources Letter from Stanley R. Marshall to J.M. Cain dated June 7, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of the referenced letter indicating that two transportation-related violations were issued against LP&L's low level waste shipment number 88-1008. This shipment arrived at the B; atty, Nevada disposal site on May 31, 1988. The refer-enced letter was received on June 14, 1988, and requires a response within 20 days of receipt. I.s is discussed in detail below, LP&L has i reviewed the violations and has initiated corrective actions to prevent j their recurrence. Violation number 001-Q446-4-1 indicates that trie placard on the front of , the transport vehicle was placed within three (3) inches of the license l plate holder, and therefore not to conformance with the requirements of I 49CFR172.516(c)(4). Photographic documentation was included in the referenced letter *o substantiate this finding. Violation number 001-Q446-4-2 indicates that several portions of the carrier copy of the shipping manifest were not clearly legible, and i
"AN EQUAL OPPORTUNITY EMPLOYER" k ______ _ _ _ _ . - - - - - _
.. .. Paga 2 W3P88-1631 July 5, 1983 therefore violated the requirements of 49CFR172.201(a)(2). This regu-lation specifies that:
The required shipping description on a shipping paper and all copies thereof used for transportation purposes, must be legible and printed (manually or mechanically) in English. Lp&L was aware prior to the shipment leaving Waterford 3 that the carrier copy of the manifest was not entirely legible, and took what it considers appropriate compensatory action. The manifest required by the disposal site is a five part carbon form, the last copy of which generally does not print clearly. As LP&L has been doing for quite sore time, the first page of the manifest was photocopied and designated as the carrier copy in lieu of the last page of the five part manifest. In fact, both the State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned . them about resolving the legibility concern. To avoid future confusion regarding which copies are used for transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest. 9 Radwaste Department Technical Procedure number RW-2-501, "Radioactive Waste Shipments" provides instructions regarding Department of Transpor-tation, Nuclear Regulatory Commission and disposal site requirements for radioactive vaste shipments. The procedure requires cospletion of ' checklises to insure that the proper paperwork and notifications have been completed, and that the shipments and transport vehicles meet the applicable regulations prior to leaving Waterford 3. In light of these violations, the procedure has been reviewed, and is being revised to be i more specific with regard to both placarding and shipping paper legibil- , ity requirements. Apprcril of the changes is expected within the next two seeks, but in any cats will be received prior to the next radioactive waste shipment. In addition, these violations and applicable regulatory requirements have been reviewed with personnel involved with radioactive waste shipments. - To insure timely respasses, please address future correspondence to me. Hy address ist a P.O. Box 60340 , Mail Unit N-17 t New Orleans, Louisiana 70160
Pas 2 3 W3P88-1631 July 5, L988 Should you require additional information regarding these violations, please contact Ms. Chadi D. Groome at (504)595-2846. Very truly yours,
. g.../
R.F. Burski Nuclear Safety & Regulatory Affairs Manager RFB/GGdsy ec: J.G. Dewease R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. LaBonte, L.A. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autrf, E. Ingersoll, J. Hornor, B. Gray, Waterford 3 hecords Center, Administrative Support (1), Licensing Library i I
LOUISI . e o. sex 60340 POWE A &ANA LIGH1/ wexaosNestsest NEW ORLEANS. LOUISIANA 70160 * (504)895 3100 IItISd Mde'0 July 25, 1988 W3P88-1623 A4.06 QA Mr. Stanley R. Marshall Department of Human Resources Health Division Radiological Health Section 505 East King Street, Room 203 Carson City, Nevada 98710 SUBJtCT: Waterford Steam Electric Station - Unit Number 3 Nevada Radioactive Waste Disposal Site Us":'s Permit . Mamber Q446 Low Level Waste Shipment Numbers 88-1009 and 88-1011 REFERENLLS: (1) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to J.M. Cain dr.ted June 30, 1988 Regarding Louisiana Power & Light Company Low Levei Waste Shipment Number 88-1009 (2) State of Nevada Department of Human Resources Letter from Stanley R. Marshall co J.M. Cain dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Waste Shipment Number 88-1011 (3? Louisiana Power & Light company Letter W3P88-1631 from R.F. Burski to Stanley R. Marshall dated July 5, 1988 (4) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to R.F. Burski dated July 12, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of references 1 and 2 which descrici transportation-related violations issued against LP&L's low level waste shipment numbers 88-1009 and 88-1011 i<hich arrived at the Beatty, Nevada disposal site on June 3, lft8 and June 6, 1988, respectively. As both violations ar the same, they are being addressed together in this letter. Also, we woul se to note that these violations are the same as violation number 001-44t 4-2, for which corrective action has been initicted, as described in reference 3 and acknowledged in reference 4.
"AN EQUAL DPPORTUNITY EMPLOYER"
Pasa 2 V3P88-1623 July 25, 1988 These two violations indicate that several portions of the carrier copy of the shipping manifests were not clearly legi',le, and therefore violated the requirements of 49CFR172.201(a)(2). This regulation specifies that: The requirad shipping description on a shipping paper and all copies thereof used for tranmrtation purpos. s, must be legible and printed (aanually mechanically) in English. LP&L was aware prior to the shipments leaving Waterford 3 that the carrier copies of the manifests were not entirely legible, and took what it considers appropriate rompensatory action. The manifest required by the diaposal site is a five part carbon form, the last copy of which generally does not print clearly. As LP&L has been doing for quite some time, the first page of the tanufs" was photocopied and designated as the carrier copy in lieu of the last page of the five part manifest. In fact, both the State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned the's about resolving the legi-bility concern. To avoid future confusion regarding which copies are used for transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest. , Radvaste Department Technical Procedure number RW-2-501, "Radioactive Waste Shipments" provides instructions regarding Department of Transportetion, Nuclear Regulatory Consission and disposal site requirements for radioactive waste shipments. The p rocedure requires completion of checklists to insure l that the proper paperwork and notifications have been completed, and that the ( shipments and transport vehicles meet the applicable regulations prior to j leaving Waterford 3. In light of these violatious, the procedure has been l revised r.o be more specific with regard to shipping paper legibility require-I mer.ts. In addition, these violations and applicable regulatory requirements have been reviewed with personnel involved with radioactive waste shipments. Should you require additional information regarding these violations, please contact Ms. Chadi D. Groome at (504)595-2846. Very truly yours, mfd-R.F. Burski Nuclesr Safety & Regulatory Affairs l Manager RFB/SS/Isy cc: J.G. Dewease R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. LaBonte, L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autry, E. Ingersoll, J. Hornor, B. Gray, N. Tucker, Waterford 3 Records Center, Administrative Support (1), Licensing Library
LO UISI AN A / 3ir esnoNNs Sineer . p o.soxecuo POWE A & L1G H T NEW LRLEANS, LOJi$ LANA 70160 * (504)595 3100
$UWYN August 4, 1988 W3P88-1630 A4.06 QA Hr. Stanley R. Marshall Department of Human R(sources Health Division Radiological Health Section 505 East King Street, Room 203 Carson City, Nevtda 98710
SUBJECT:
Waterford Steam Electric Station - Unit Number 3 Nevade 13dinactive Waste Disposal Site t'ser's Permit Number Q446
- Low Level Waste Shipment Number 88-1010 PEFERENCES: (1) State of Nevada Department of Human Resources Letter from Stanlef R. Marshall to J.h. Cain dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Waste Shipment Number 88-1010 (2) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to Chadi Groome dated July 18, 1988
Dear M.,
Marshall Louisiana Power 6 1ight Company (LP&L) is in receipt of the referenced letters discussing transportation-related violations issued against LP&L's low level waste shipment number 88-1010. This shipment arrived at the Beatty, Nevada disposal site on June 6, 1988. As is discussed in detail below, LP&L has reviewed the violations and has initiated corrective actions to prevent their recurrence. Violation number 003-446-2-1 indicates that contrary to 49CFR173.425(b)(1), which requires that "Materials must be packaged in strong, tight packages so that there will 'oe no leakage of radioactive material under conditions normally incident to transportation", package number 88-0111 was found to have a hole approximately is inch in diameter on the front of the package. The violation continues that "No loss of container contents was found as a result of the hole in the package." While LP&L is not minimizing the seri-ousness of a breach of integrity in a shipping package, it is important to note that this small hole did not result ir leakage of radioactive material, and therefore the package met the intert oli the cited regulation.
"AN EQUAL OPPORTUNITY EMPLOYER"
Page 2 W3P88 1630 As a result of this violation LP&L has taken several steps to insure ene integrity of its shipping packages. Packages already on site were reinspected. Radwaste Department Technical Procedure numbers RW-2-501, "Radioactive Waste Shipments", and RW-2-300, "Receipt, Storage and Loading of Shipping Contain-ers", have been revised to clarify acceptance criteria and focus both receipt i and final (prior ta shipment) inspections on box integrity. Furthermore. l while not a regulatory requirement for this type of container, procurement specifications have been upgraded to Quality Class II which imposes more stringent controls on both the vendor and LP&L. V u .ation number 003-Q446 3-1 indicates that the subject shipment did not meet the requirements of 49CFR173.425(b)(6) and 49CFR173.448(a) in that "the containers were found to have shifted to the front of the trailer as a result of the wooden wedges being released from between the containers during transit. The release of the wedges created approximately 6 inches of space between the rear floor bracing materials and the rear packages." The cited regula-tions specify, respectively: , Shipment must be braced so as to prevent shifting of lading under conditions normally incident to transportation. and Each shipment of radioactive materials shall be secured in order to prevent shifting during normal transportation conditions. In response to this violation, LP&L has thoroughly reviewed its loading practices and discussed the incident with personnel involved with radioactive waste shipments. Extreme care was taken in preparing this shipment for transportation. The methode employed to secure the boxen should have been adequate to prevent the cargo from shifting to any appreciable degree, and an explanation of the loading procedures is in order at this time. The ship-ment consisted of ten boxes. The boxes were centered in the trailer, one behind the other, with the first box placed flush against the front wall of the trailer, and each subsequent box abutting the box in front of it. (Becausa the boxes bow slightly when full, the tops of the boxes could not be placed squarely against each other.) Two by fours were nailed to the floor of the trailer around each box to keep the boxes in place during transit. A restraining device (a metal bar and ratchet mechanism) secured to the sides of the r ailer (approximately three-fourths up from the bottom of the box) was inua41ed behind the fourth box to further inhibit movement and another was installed behind the last box to keep the cargo from moving backward toward the trailer doors. In addition, cargo straps were strung from side to side in the trailer behind every other box. Because the boxes were slightly bowea and the tops could not abut, wooden wedges were driven between the boxes to further maintain the existing spacing and provide shock absorption. 1
.. .. l l
Page 3 t W3P88-1630 ' i i Apparently some of these wedges vibrated free and gave the appearance that i the load may have shifted. As the wedges were not r9cessary to secure the shipment, they will not be used for future shipments. As-reference 2 rescinded violation number 003-Q446-3-2, the third violation i cited in reference 1 this violation does not require a response. However, , LP&L wishes to point out that its efforts in investigating the violation identified the differences between the information presented in the viola- ! tion and LP&L's documentation for the subject shipment. These differences ; were confirmed by the l'.S. Ecology Site Radiation Safety Of ficer during a ! telephone call with LP&L personnel. The violation cites discrepancies between ' radiation levels measured at the disposal site and those indicated on the ; shipping manifest for three boxes. Two box numbers 047 and 049, do not ' match any box numbers on LP&L's manifest. The third box number, 0111, was indicated on the manifest. However, the violation specifies that the manifest 3ndicated a radiation level of 800 mR/hr for this box, while the aighest radiation level of any . box in the subject shipment was 500 mR/hr , contact. As the documentation clearly indicates, these radiation level dis- , crepancies could not have been cited against ths subject shipment, and LP&L l appreciates your letter rescinding this violation. I i Should you require additional information regarding these violations, please i contact Ms. Chadi D. Groome at (504) 595-2846. I Yours very truly, i R.F. Burski i Manager ; Nuclear Safety & Regulatory Affairs I RFB/CDClple ces J.G. Dewease, R.P. Barkhurst, N.S. Carns P.V. Prasankumar, W.T. LaBonte, } J. Ridge 1, L.R. Simon, D.B. Stevens, M.J. Meisner, C.E. Wilson, ! W.H. Spell, V. Autry E. Ingersoll, J. Hornor, 3. Gray, N. Tucker. l Watsrford 3 Records center Administrativo support, Licensing Library . i t { t
DOCUMENTATION OF TELEPHONE C0HNUNICATIONS DATE: September 9, 1988 TIME: 1000 A,M, ggg, B.C. Motrison, C.D. Croome PARTY CALLING: J.A. Ridge 1, L.R. Simon / . LP&L (Nake) f sCompany) H.D. Chaney R.E. Baer NRC. Region IV PARTY ANSWERING: (Name) (Company)
SUBJECT:
IR 88-20 FILE: A7,09 _ , _ QA
SUMMARY
- (INCLUDING DECISIONS AND/OR COMMENTS)
Chadt discussed the Nevada violations and indicated that all items had been taken care of. The NRC wants a summary of the problems and resolutions in a formal letter. Chaney addressed the training response required by IR 88-20. He wants us to formally document our commitment to IEB 79-19 items 5 and 6 and how we are going to keep the Radwaste Training up-to-date. i W ACTION REQUIRED: i Chadi will submit a letter on Nevada questions. Barbara and Marcy Langan will prepare response to training question. DISTRIBUTl]N: Records Center, Administrative Support, Licensing Librarv. Site Licensir.g Support File I
' 8. * ..
UNITED sTATt*J ['gp ag 8go f > g- ( e NUCLFAR CECULATORY r REGloN IV e, 011 RYAN PLAZA ohiVE, bl.lTC 'N00 ,
%, e' ..e
.% / / ARLINGTON. TEXAS ) .,1)
Alf 2 4 W RECEIVED O> In Reply Refer To: r._ ADMINISTRATIVE SUPPORT Docket: 50-382/88-20 lW SEP 1 Louisiana Power & Light Company G " ATTH: J. G. Dewease, Senior Vice President . Nuclear Operatioas , 317 Baronne Street New Orleans, Laufstana 70160 Gentlemen: This refers to the inspection conducted by Mr. H. D. Chaney of this office during the period July 10-15, 1988, of activities authorized by NRC Operating License NPF-38 for the Waterford Steam Electric Station, Unit 3, and.to the discussion of our findings with Mr. N. Carns and other memoers of your staff at the conclusion of the inspection. Areas examined during the inspection included transportation of radioactive materials and low-level solid radioactive waste management. Within these areas, the inspection conshted of selective examination of procedures and representative records, interviews with personnel, and observations by the NRC inspector. The inspection findings are documented in the enclosed inspection i report. Within the scope of the inspection, no violations or deviations were identified. However, we are concerned about the inictivity of your training program for ! radioactive waste (radweste) workers and persornel involved in radioactive material transportation activities. Accordingly, you are requested to respond, in writing, within 30 days of the date of this letter, outlining steps taken to ensure that initial training and retraining programs are fully implemented for personnel in the onsite radwaste group that satisfies NRC Inspection and Enforcement Bulletin 79-19 commitments and current industry practices. Your response should address the root causes of why the previously established program was allowed to become inactive, and the short and long tem actions to be taken to improve and maintain the training ; program in the future. l
- One unresolved ites is identified in paragraph 6 of the enclos;d inspection -
report. , i The response diracted by this letter is not subject to the clearance procedures of the Of fice of Management and Budget as required by the Papenvork Reductioh Act of 1980, PL 96-511. 1 1 t i QQ O 2$ R h h
^
i pQf]flV'fJ^-_ . .-
a. Louisiana /ower & Light Company
- Should you have any questions cor.cerning this inspection, we will be pleased to discuss them with you.
Sincerely,
^
\f t/ w b.ac t) s/ L. J. Callan, Director DivisionofReactorProjects
Enclosure:
f.ppendix - NRC Inspection Report 50-382/88-20 cc w/ enclosure: ' Louisiana Power & Light Company , ATTN: G. E. Wuller, Onsite Licensing Coordinator
+
P.O. Box 8 Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager . P.O. Eox B Killona, Louisiara 70066
. Middle South Services
< ATTN: Mr. R. T. Lally P.O. Box 61000 New Orleans, Louisiana 70181 1 Loutstana Power & Light Company ATTH: R. F. Burski, Acting Manager Nuclear Safety and Regulatory Affairs l 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 Louisiana tadiation Control Prograa Director J t I 1.
e, APPENDIX U.S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-382/88-20 Op3 rating License: HPF-38 Doctet: 50-382 Licensee: Louisiana Power & Light Coapany (LP&L) 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (WAT-3) Inspection At: WAT-3 site, Taft, St. Charles Parish, Louisiana Inspection Conducted: July 10-15, 1988
\
Inspector: b'- 1 I 17 ! H. D. Chade?) Radiation Specfalist, Facilities Date Radiological Protection 54 tion i Approved: 7M '
. . Baer, Chief, Facilities Radiological Date Protection Section t
Inspection Summary inspectionConductedJuly 10-15, 1988 (Report .40-382/88-20) i Areas Inspected: Routine, unannourced inspection of transportation of ! radioactive materials and low-level radioactive waste (LLRW) management. > r Results: Within the areas inspected, no violations or deviations were identified. One unresolved item concerning the transportation of radioactive materials was identified (see paragraph 8). e A $ f E_ - DD ~[ W I Y $ A N
.t. ..
g DETAILS I
- 1. Persons Contacted .
f LP&L t
*N. Carns, Plant Manager 4
*S. Alleman, Quality Assurance Manager F. Davis, Nuclear Operations Support and Assessment Engineer -
G. Espenan, Nuclear Operations Support and Assessment Engineer R. Kenning, Nuclear Operations Support and Assessment Engineer
*W, LaBonte, Radiation Protection Superintendent :
J. Ladet, Security Supervisoe, Operations "M. Langan, Technical Support Training Supervisor D. Landeche, Health Physics (HP) Supervisor . . M. Marler, HP Trainer i R. McLendon, Dosimetry Gupervisor i
*P. Prasankumar, Assistant Plant Manager, Plant Technical Services '
S. Ramzy, Assistant Radiation Protection Superintendent "J. Ridge 1, Assistant Radiation Protection Superintendent
*D Stevens, Radwaste Supervisor Others
*T. Staker, NRC Resident Inspector
- Denotes attendance at the exit interview. .
The NRC inspector also contacted other licensee personnel including i administrative, security, and quality assurance (QA) personnel. : i
- 2. NRC Inspector Observations !
i The following are observations that the NRC inspector discussed with the l licensee curing the exit interview on July 15, 1986 and (observation b. - which was discussed with R. Kenning) by phone on July 19, 1988. These observations :re not violations, deviations, unresolved items, or open l items. These observations were identified for licensee consideration for ( program improvement but the observations have no specific regulatory , requirement. TheIIcenseestatedthattheobservationswouldbereviewed ! (no coeniteent was made in regard to observation b.). . ;
- a. Clean Waste Release - The procedure currently in use for the testing f of ganea scintillation counting of bulk paper and plastic wastes to 1 be released for unrestricted use is not signed or dated. {
I l i
). .
3
- b. Radwaste Program Assessr.ents - Neither the Corporate Nuclear Support
~
TerviceT 5ection nor the onsite Operations Support and Assessment Group routinely performs assessments on low-level solid radwaste'and transportation activities.
- 3. OpenItemIdentifiedDurinaThisjnspection An open item is a matter that requires further review and evaluation by the NRC inspector. Open items are used to document, track, and ensure adequate follow-up on matters of concern to the NRC inspector. The following open item was identified:
Open Item Title See Paragraph 382/88?0-01 Retraining of Radwaste Staff 6
- 4. Unresolved Item Identified Ourina 1his Ing,ection An unresolved item is a matter about which more information it, required to i ascertain whether it is an acceptable item, a deviation, or a violation. .
The following unresolved item was identified:
; Oyen Item , Title See Paragraph 382/8820 02 State of Nevada Identified 8
, Transportations Regulation Violations
- 5. Organization and Management Controls - Transportation /Radwaste
~ ~
(83522/83722) i The NRC inspector inspected the licenswe's staff assignments including: i organization, assignment of responsibilities, authorities, staffing, identification and correction of problems, audits and surveillances, 1 communication to esployees, documentation and implementation relating to r radioactive effluents and solid wastes, and the tNnsportation of ' l radioactive materials to determine adherence to commitments contained in l Sections 11 and 13 of the Updated Final Safety Analysis Report (UFSAR), t and NRC inspa-tion and Enforcement Bulletin (IEB) 79 19 l, and compliance with Technical Specification (TS) 6.2, 6.8, and 6.13. [ i l The NRC inspector reviewed the organization of the licensee's radwaste
; department which is responsible for management of solid radioactive waste processing and transportatien of radioactive materials (RAM). The NRC l
inspector also reviewed the LP&L Corporate support (Nuclear Support i i Services Section) provided the WAT-3 radwaste program. - l
- The NRC inspector reviewed the licensee's senior management policies t (Nuclear Operations Management Manual), which included the assignment of L 1
responsibility for RAM shipments, implementing procedures for control of LLRW processing and transportation of RAM, the NRC approved Process j J
4 l Control Program (PCP) (Procedure RW-01-210), field quality control a;tivities, and the NRC approved QA program (Docket: 71-0604) for ' 4 transportation activities. The licensee utilizes an ancillary speciai
! scope QA program in conjunction with their 10 CFR Part 50, Appendix B, QA program for ensuring quality in RAM transportation activities. Frocedures ,
and other documents reviewed during the inspection are listed in the l Attachment to this report, t ~ The NRC inspector reviewed the licensee's audit program including current and planned audits for LLRW and RAM transportation activities. The following audits and surveillances were reviewed: : i
- Surveillance QS-88-055, Purchase Orders and Receipt Inspection of i Shipping Packages i i
j
- Audit SA-87-024.1, Radwaste Processing l l
- Audit SA-87-003E.1, Radwaste Training and Qualifir.ation 1
- Audit A39.356-61.1, Container Products Corporation (Vendor Audit) l d !
The licensee's audits were found to be comprehensive and included an ; 4 adequate amount of performance based objectives. The NRC inspector noted ; l tnat while tne Nuclear Operations Support and Assessment (NOSA) Group ; , performed operational assessments on most other activities at WAT-3, NOSA l does not perform assessments in the area of radwaste operations. ! f j No violations or deviations were identified. ;
- 6. Training and Qualification - Transportation /Radwaste (83523/8_3723) l j The NRC inspector reviewed the licensee's training program including
- adequacy of training, employee' knowledge, qualification requirements, 4
position descriptions, technician, contract technician screening and i training, audits, and training not covered by INP0 accreditation to ; determine agreement with commitments in Section 13.2.2.8 of the UFSAR, . j and NRC IEB 79-19, and compliance with the requirements of Technical : Specification (TS) 6.3 and 6.4. l t 1, 1he NRC inspector observed work practices and interviewed radwaste group personnel. The licensee's biennial ren "41fication program for personnel involved in radwaste processing and tn sportation activities was reviewed J i fur adequacy. Training records for the plant staff (approximately . i 21 radweste and HP individuals) involved in the processing and i I j transportation of RAM were reviewed for completeness. The NRC inspector i also reviewed the licensee's implementing procedures and lesson plans for l j the training of radweste personnel. The NRC inspector noted (this was (' also identified during a QA audit) that at least four radweste personnel j have not received any formal radwaste training since hiring on at WAT-3, None of these persons appeared to have performed radwaste processing l
- activities other than collection of waste. The last, training for many I t I '
1 i l i l
o P., .. 5 radwaste personnel was the completion of on-the-job training checklists in 1986. The NRC inspector noted that the licensee had provided many individuals with required reading of procedural changes and vendor
- provided training on radwaste and transportation activities in 1986 and 1987 which satist'les the biennial requalification requirements. The NRC.
inspector also noted that the lesson plans for the radwaste training program were not current (1984 viitage) in the areas of regulatory requirements and licensee facilities. The licensee training program for radwaste workers was an item of concern in NRC Inspection Report 50-362/85-26 and resulted in the issuance of a Notice of Violation (NOV) fer the failure to ensure that a contract worker received proper training. This area was strengthened as a result of the NOV. The Nuclear Training Department (NTD) staff positions responsible for radwaste group training activities have had a high turnover rate in the past which has resulted in the progrem not being maintained in a current status. The licensee's NTD had filled the vacant position of instructor for the radwaste group around July 1, 1988. The licensee's radwaste training program will be considered an open item pen <1ing licensee implementation of an upgraded training and requalification program for radwaste workers (382/8820-01). No violaticht or deviations were identified.
- 7. Solid Radioactive, Waste (845?2/84722)
The NRC inspector reviewed the licensee's program for the control, classification, characterization, and shipment of low-level radioactive waste to deterr.ine agreement with the commitments contained in Section n of the UFSAR and compliance with the requirements contained in TS 3.11.3, 4.11.3; 10 CFR Puts 20.301, 20.311, 61.55, and 61.56; and the recommendations of NRC Branch Technical Position (BTP) papers on LLRW classification and weste form. The NRC inspector reviewed the licensee's coeputerized program for management of waste processing and packaging activities (RADMAN). The licensee's biannual evaluation of waste streams and development of isotope correlation factors were reviewed. The licenset's LLRW characterization and classification program is well documented. The NRC inspector reviewed the licensee's vendor provided processes for dewateiing of filters and rasins. The licensee's PCP and the licensee's vendor's PCP for the processing of various waste streams were reviewed for management conteni over changes and revisions. The NRC inspector reviewed selected records of waste processing activities (resin solidification, filter dewater.ing, dry active waste compaction, and oil solidification) for 1987. The NRC inspector reviewed the licensee's records for LLRW shipped since 1985. The following tabulation shows the total volume of LLRW shipped for the 1985 through 1987.
e., .,
'. 6 Volume Shipped (Cubic feet)
Year Goal Actual Curie Content 1985 5,000 9,997 33.5 ' 1986 6.227 6,138 37.5 1987 8,000 13.530* 178.2 aincluded approximately 5,000 cubic feet of boric acid concentrator bottoms held over from 1985 due to licensee efforts in evaluating onsite burial. No violations or deviations were identified.
- 8. Transportation (86721/86740)
The NRC inspector reviewed the licensee's program for transportation of RAM, program audits, procurement and evaluation of packaging, determination of package activity, preparation of packages for shipment, maintenance of packages, delivery of packages to carrier, and the receipt of RAM for compliance with the requirements of 10 CFR Parts 20.205 and 20.311; 10 CFR Part 71; and Department of Transportation'(DOT) regulations (49 CFR) incorporated by 10 CFR Part 71. The NRC inspector reviewed 30 shipping records from the 1986 and 1987 period for completeness and accuracy. The licensee's authorization to t utilize specific shipping packages was verified. The NRC inspector reviewed the documentation including advanced notification, package opening and closing checklists, hazardous waste manifests, sole use : instructions, and survey records. The NRC inspector noted tnat the licensee routinely used extensive checklists for accomplishing shipments of RAM. The NRC inspector was informed, on July 11, 1988, by the licensee, that LP&L had been notified by the state of Nevada that several violations of DOT and burial site requirements had be identified during inspection of two of the licensee's waste shipments to the Beatty, Nevada, burial site (May 1988, 'tadioactive Shipment Record (RSR) 88-1008 and June 1988, RSR 88-1010). The viciations identified by the state of Nevada included radiation dose rates on waste containers significantly greater than shipping records indicated, a waste container (strong tight package for low-specific-activity shipment (s)) was found to have a b inch hole in it (manufacturing defect), improper location of DOT required placard, illegible manifest copies, and the bracing used in a sole-use enclosed trailer-van came loose and allowed the load to shif t. The licensee.had not fully investigated each of the apparent violations at the time of this inspection. The licensee had instituted an immediate inspection of waste containers used for the shipment of dry active waste (DAW). The licenseo determined that several of the onsite ready for use Container Product Corporation's 8-25 containers (steel boxes of approximately 95 cubic fett capacity) contained manufacturing defects. These containers are not required to be M T approved or NRC certified. The hole in the B-25
container, found by the state of Nevada, was the result of a weld burn-through that was painted over at the manufacturing facility and was not readily identifiable during the licensee's proceduralized preuse inspection of the container. At the time of this NRC inspection, the licensee had already instituted corrective actions concerning potontial - defects in waste containers used for DAW packaging and had revised their receipt inspection program for strong, tight containers of all makes. The licensee informed the NRC inspector by telephone on July 18, 1988, that preliminary investigation of the apparent high dose rates on waste containers may be the result of a state of Nevada mix up involving another shipper's material and not LP&L's. NRC enforcement will be deferrec until all of the state of Nevada's violations have been resolved. The licensee's apparent violation of HRC and 00T regulations will be considered an unresolved item pending further review by the NRC during a future inspection (382/8820-02). The N'lC inspector noted that the licensee's QA department had just completed a surveillance of waste packaging procurement and receipt inspection. The draft results of the surveillance indicated that several deficiencies were identified in the licensee's program for these materials. The licensee had not experienced any transportation incidens which caused a reduction in the effectiven.ss of an NRC or DOT certified packaging since the previous inspection. No violations or deviations were identified.
- 9. Review of Periodic and Special Reports (90713)
The NRC inspector reviewed the licensee's semiannual effluent reports for 1986 through 1987 for compliance with the requirements of TS 6.9.1.8, 6.13, and 6.15 and the recomme.idations of RG 1.21. l l The licensee's semiannual reports for the years 1985, 1986, and 1987 werc l reviewed and compared to the licensee's documentation concerning radioactive material shipments (solid LLRW disposal), PCP changes, and modificationr, to the solid LLRW processing systems. No violations or deviations were identified.
- 10. Exit Interview .
The NRC inspector met with the NRC resident inspector and licensee I representatives denoted in paragraph 1 on July 15, 1988, and summarized the scope and findings of the inspection as presented in this report. The licensee agreed to provide the NRC with all correspondence involving the state of Nevada's 1988 inspection and enforcement actions concerning LP&L.
P,. P .. 41 T6CHMLl41 e', 70 tabt. ItGFEC TICM REFOkl 50 .'82/89-20 LLO. cwt 1FJ!LS._F1 VIEWED i illbE Egyl$1Cfj ppTE tJuc l epr ,Oppr4t t ont _Utnegegient _ Manual, t Section VI. Special Scope Ovality Pol i c t vis L Chapter 5. Radio 6ctive Waste Management 3 12-21-87 j l Elout.Vestettoos._Meou.3t , Volume 20. Radioactive Waste Manaovment Frocedures [ RW-01-100 Radioactive Waste Reduction 2 02-18-57 RU-01-200 Record Preparation. Filino. and Storage 1 06-26-87 i RW-01-210. Frocess Control Program 2 07-10-87 RW-02-100. Waste Material Collection and , Handlino 4 03-25-88 RW-02-110. Waste Sample Collection and Isotope Evaluation 3 05-18-87 RW-02-120. Handling Used Protective Clothing 0 07-14-86 , RW-02-200. Packaging Radioactive Solid Waste (DAW) for Disposal 5 08-20-86 RW-02-210. Radioactive Waste Solidification 6 10-26-87 L I RW-02-200. Radwaste Filter Disposal 2 01-07-86 3 06-00-88 ! RW-02-200. Waste Material Segregation FW-02-231. Granulating Material for Disposal 2 03-29-88 l Blowdown Dominera11:er Resin [ RW-02-240 Transfer 0 04-07-86 f RW-02-300. Receipt. Skorage and Loading of Shipping Containers 2 05-23-86
'W-00-310. Storage of Loaded Shipping Containers 3 09-15-86 RW-02-300. Packaged Radioactive Waste Control and Inventory 5 06-06-87 RW-00-330 Radioactive Waste Tracking 1 02-18-86 RW-02-401. Use of Radman Operating Program 0 08-27-87 RW-02-411. Use of Radman Data Manager 0 . 09-10-87 RW-02-420, Oper ati on of the Filtrk Computer Prog-am 0 05-04-87 RW-02-430, Operation of the RAMSHP Computer Program 1 06-01-88 RW-02-500. Radioactive Material Shipment 3 .09-15-87 RW-02-501. Radioactive Waste Shipment 1 04-08-88 t
RW-02-521. Type and Quantity Determination 0 05-05-87 RW-02-530. Decay Heat Calculations for USNRC Certified Containers 0 05-05-87 RW-02-541. Hydrogen Gas Calculati on 0 05-04-87 02-18-86 RW-02-800. Dose to Curie Conversion 1 02-18-86 RW-02-810. Waste Classsfication 1
w t *. o t es i 3 T L I- H. .'l i ! CH : L i1 E Wn dor , [ r, oc u ter p 5 F 1 -' 813. LN Technol oos e.u Fr oct u Cont rol Fr oor ani for Dewsterano Ltners G Unl nour. SS-Onl. LN Twetitioloot os Froccus Contrul h oorane for Radwate Solidtfication K 05-05-87 M - a' ' 5. O npretinu Frocedure for LN Technolooken Radwas,te Solidiftuation S v s t o... a6908 - G Untnowre NrsC Apter oved Topscal Poport PS-53-n378. NUS Radwaste Solidification System - 05-30-85 Nugjgat,Ita10109,Dggett@ ggt _ECQce4ytv6 NTC-207 Radweste Services Training Frogram 2 04-07-8B 1,94too_ Ele 05 TO20-000-01. Radwaste Helper Final Exam 1 01-23-96 T001-000-01. Radwaste Helper - Radwaste Frogram Overview 1 09-28-84 TOO1-001-00. Radwaste Helper - Nuclear Power Orientation O 09-28-84 T001-002-00. Radwaste Helper - WAT-3 Radwaste Systems 0 09-28-84 TOO2-000-01, Radwsste Helper - folit Radwaste Compaction 1 09-26-84 TOO3-006-01. Radwaste Helper - Radwaste Solidification 1 09-28-84 W3TOO4-OOO-OO. Radwaste Helper - Radioactive Material Classification and Qualification 1 04-18-83 W3TOO4-001-OO. Raawasto Helper - Radioactive Material Packaging - 04-18-83 W 3'. '4-002-00. Radwaste Helper - Marking. Labeling. Placarding Requitament for Shipments - 04-18-83 WOTOO5-OOO-OO. Radwaste Helper - Radioactive Material Shipping Papers - 04-18-83 T017-000-00. Radwaste Helper - Radtoactive Shipments O 09-28-84 T018-000-00, Radwaste Helper - Dry Waste Segregation O 03-11-05 T901-OOO-00 Radman Software O 08-30-84 00:Ibe: Job _Iteintoe_Cbechlista T501-000-CO. Basic Radwaste - 05-02-86 T506-000-01, Radwaste Equipment Opwration - 09-08-86 T500-COO-DO. Handling and Control of DAW - 05-02-86 T503-OOO-OO. Packaging of DAW - 05-02-86 T510-000-00. Radioactive Matertal/Radwaste - 05-02-86 Shipping T511-000-00 Contract Decon Technician Quals - 07-30-86 2
o.- s e c>. g Yur;d e.e: t., t1a n.is t + .and tJF G Lirt t . '. c a t- ) m .: . - C h en.-rJuc l e a r Cast 14-19CH. Co+C 4+i*4 C h s .n-tJu c 1 e a r Cast 8-120B. CofC ?P . Lr4 lechnolootes Cost USA /9151eA. Co t C G 1 ";1 TJUS Cast 7-100. Co+C 4080 L I G en F H9_C OCC %D 70(190W tritor-OH i ra Corresoorid ence. S. Develle (LFtL) to file.
Subject:
!E J Bullet.tn 79-19. Fackaging of Low-Level Radioactive Waste for Transoort and (
):urial". dated Julv 19 1985. Ser s ,1 TJo. WOF83-0488 l l
l 1 l l O e p 3
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