ML20209F854

Insp Rept 50-382/87-06 on 870323-27.Violations Noted:Failure to Properly Control,Store & Protect QA Records.Unresolved Item Identified Re Certified Packaging Registration

ML20209F854
Person / Time
Site:	Waterford
Issue date:	04/14/1987
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20209F811	List: ML20209F805 ML20209F827 ML20209F854
References
50-382-87-06, 50-382-87-6, NUDOCS 8704300406
Download: ML20209F854 (7)

See also: IR 05000382/1987006

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-382/87-06 License: NPF-38

Docket: 50-382

Licensee: Louisiana Power and Light Company (LP&L)

317 Baronne Street

P. O. Box 60340 -

New Orleans, Louisiana 70160

Facility Name: Waterford Steam Electric Station, Unit 3 (Wat-3)

Inspection At: Taft, St. Charles Parish, Louisiana

Inspection Conducted: March 23-27, 1987

Inspector: \/ dl A 0.3lh4tr/// NI

J. B. Nicholas ~, Senior fadiation Specialist Date

.f04FacilitiesRadiologicalProtectionSection

Approved: ( f4O}lMA@n /

B.Murray, Chief,FacflitiesRadiological Date

Protection Section/

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Insp1ction Summary

Inspection Conducted March 23-27, 1987 (Report 50-382/87-06)

Areas Inspected: Routine, unannounced inspection of the licensee's solid

radioactive waste and transportation programs including: organization and

managnent controls, training and qualifications, solid radioactive waste

packaging, radioactive waste management, transportation activities, and

low-level radioactive waste storage facilities.

Results: Within the areas inspected, one violation was identified (failure to

properly control, store, and protect quality assurance records, paragraph 4).

One unresolved item was identified (certified packaging registration,

paragraph 5). .No deviations were identified.

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DETAILS

1. Persons Contacted

LP&L

• R. P. Barkhurst, Vice President-Nuclear, Nuclear Operations

S. A. Alleman, Assistant Plant Manager, Technical Services

• J. R. McGaha, Acting Plant Manager

• P. N. Backes, Acting Nuclear Quality Assurance (QA) Manager

• K. L. Brewster, Operations Licensing Engineer

• J. L. Etheridge, Radwaste Engineer, Nuclear Special Projects

W. M. Finnerity, Operations Training Instructor

• C. R. Gaines, Staff Assistant

T. O. Gray, Supervisor, Operations QA

• W. T. LaBonte, Radiation Protection Superintendent

R. P. Lee, QA Auditor, Operations.

G. G. Miller, Health Physics Training Instructor

W. M. Morgan, Manager, Vendor QA

• J. M. O'Hern, Training Superintendent, Technical Support

• P. V. Prasankumar, Acting Assistant Plant Manager, Plant Services

• D. M. Rieder, Radwaste Associate Engineer

• L. R. Simons, Radwaste Engineer

• D. B. Stevens, Radwaste Supervisor

• G. E. Wuller, Operations Licensing Engineer

• J. J. Zabritski, Acting QA Manager, Operations

Others

J. G. Luehman, NRC Senior Resident Inspector

A. W. Grella, NRC Senior Health Physicist (Transportation)

• Denotes those present during the exit' briefing on March 27, 1987.

2. Inspector-Observations

The following are observations the NRC inspector discussed with the

licer.see during the inspection and at the exit briefing on March 27, 1987.

These observations are neither violations nor unresolved items. These

items were identified for licensee consideration for program improvement,

but they have no specific regulatory requirement.

a. Radwaste Segregation Facility - The licensee had not established an

efficient, well maintained, and permanent area for the surveying and

segregating of contaminated materials for radwaste processing.

b. Low-Level Radioactive Waste Storage Facility - The licensee does not

have inside weather-tight storage for the present quantity of

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low-level radioactive waste which is awaiting segregation,

processing, or shipment to a burial site. The present facilities do

not provide handling, packaging, and transport loading areas.

c. Tracking of Radioactive Waste Shipments - The licensee did not have

in a procedure detailed steps to track, investigate, and make

required notifications following incidents of overdue or not received

shipments of radioactive waste materials.

d. Defective Type B Packages - The licensee did not have a procedure to

define and perform the required notifications regarding defects in

Type B packages.

e. Hazardous Materials Incidents - The licensee did not have a procedure

to perform the required immediate notification following certain

hazardous materials transportation incidents,

f. Record Requirements - The licensee had not provided sufficient detail

in the radwaste procedure RW-1-200, " Records Preparation, Filing, and

Storage," Revision 0, dated November 19, 1984, to incorporate the

requirements of Nuclear Operations Procedure (N0P)-003, " Records

Management System," Revision 2, dated February 19, 1987, which

directs Wat-3 procedures to contain as a minimum a list of records

generated as a result of performing the procedure, interim storage

requirements for the records, and the frequency of submittal of the

records to project files for final retention.

3. Program Areas Inspected

The following program areas were inspected. Unless otherwise noted, the

inspection was completed and revealed no violations, deviations,

unresolved items, or open items. Notations after a specific inspection

item are used to identify the following: I = item not inspected or only

partially inspected; V = violation; D = deviation; U = unresolved item;

and 0 = open item.

Inspection Procedure Inspection Requirements

83722 Radiation Protection, Plant _Chamistry, and

Radwaste: Organization and hanagement Controls

(Minimum / Basic)

02.01 - Organization - I

02.02 - Staffing - I

02.03 - Radiation Protection Manager - I

02.04 - Identification and Correction of

Weaknesses - I

02.05 - Audits and Appraisals - I

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83522 Radiation Protection, Plant Chemistry, Radwaste,

and Environmental: Organization and Management

Controls (Supplemental)

02.01 - Organization, Responsibilities, and

Authorities - I

02.02 - Staffing - I

02.03 - Identification and Correction of

Weaknesses - I

02.04 - Audits and Appraisals - I

02.05 - Communication to Employees - I

02.06 - Documentation and Implementation - I

83723 Training and Qualifications: General Employee

Training, Radiation Safety, Plant Chemistry,

Radwaste, and Transportation (Minimum / Basic)

_ 02.01 - Training Adequacy - I

02.02 - Employee Knowledge Retention - I

02.03 - Transportation /Radwaste Training - I

02.04 - Staff Qualification Requirements - I

02.05 - Replacement Personnel - I

02.06 - Accreditation Status - I

02.07 - Audits and Appraisals - I

02.08 - Identify Training not Covered by

Accreditation - I

83523 Radiation Protection, Plant Chemistry, Radwaste,

Transportation, and Environmental: Training and

Qualifications (Supplemental)

02.01 - Training and Qualifications Program - I

02.02 - Education and Experience - 1

02.03 - Adequacy - I

84722 Solid Wastes (Minimum / Basic)

02.01 - Audits and Appraisals

02.02 - Changes

02.03 - Processing and Storage

02.04 - Disposal of Low-Level Wastes

84522 Solid Wastes (Supplemental)

02.01 - Solid Waste System Construction and

Installation - I

02.02 - Liquid Leakage, Overflow, and Spillage

02.03 - Sampling

02.04 - Test Program for Solid Waste System

02.05 - Test Completion for Solid Waste System

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02.06 - Process Monitors - I

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02.07 - Programs, Plans, and Procedures for

Solid Waste System

02.08 - Disposal of Low-Level Wastes

84850 Radioactive Waste Management - Inspection of

Waste Generator Requirements of 10 CFR 20 and ,

10 CFR 61

02.01 - Management Controls

02.02 - Quality Control (QC)

02.03 - Waste Manifests

02.04 - Waste Classification

02.05 - Waste Form and Characterization

02.06 - Waste Shipment Labeling

02.07 - Tracking of Waste Shipments

'- 02.08 - Disposal Site License Conditions

86721 Transportation (Basic)

02.01 - Audits and Appraisals

02.02 - Procedures

02.03 - Procurement and Reuse of Packagings

02.04 - Implementation

02.05 - Transportation Incidents

86740 Inspection of Transportation Activities

02.01 - Management Control

02.02 - Indoctrination and Training Programs

02.03 - Audit Program

02.04 - Quality Assurance Program

02.05 - Procurement and Selection of Packagings

- U (see paragraph 5)

02.06 - Preparation of Packages for Shipment

02.07 - Delivery of Completed Packages to

Carriers

02.08 - Receipt of Packages

02.09 - Periodic Maintenance of Packagings

l 02.10 - Records and Reports - V (see

paragraph 4)

65051 Low-Level Radioactive Waste Storage Facilities

02.01 - Basis for Construction

02.02 - Quality Assurance

02.03 - Procedures for Construction

02.04 - Review of Construction

02.05 - Organization and Staffing

02.06 - Training and Qualifications

02.07 - Startup and Operations Procedures

02.08 - Effluent Monitoring Changes

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[ 4. Apparent Violation

'86740, Item 02.10 - Records and Reports

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On March 23, 1987, the NRC inspector noted that the completed original

. lifetime QA records' generated from radioactive waste shipments made.during

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1986 and 1987 were: stored in an unlocked standard file cabinet in the

Radwaste Supervisor's office in the reactor auxiliary building and had not

- been transmitted to plant records management for final retention. The

licensee's Technical Specification 6.8.1 requires that written procedures

be established, implemented, and maintained covering.the activities

referenced in~ Appendix. A of Regulatory Guide 1.33, Revision 2, dated

February 1978. _ The licensee's Nuclear Operations Management

i Manual (NOPM),Section V, Appendix A, " Regulatory Guidance Documents,"

Revision 1,. dated August 12,.1985, contains a listing of ANSI standards

and Regulatory Guides which LP&L is committed to for operation of Wat-3.

Regulatory Guide 1.88, " Collection, Storage and Maintenance of Nuclear

. Power Plant Quality Assurance Records for Nuclear Power Plants" and

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ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance

of Quality-Assurance Records for Nuclear Power Plants" are included in

3. that list. NOMM,Section VI, Chapter 5, " Radioactive Waste Management,"

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Revision 2, dated February 14, 1986, states in paragraph 3.2.15(g) that

the quality records program applies to records relating to packaging and

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shipment of radioactive waste material. N0P-003, " Records Management

System," Revision 2, dated February 19, 1987, in paragraph 3.5 defines

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records as being QA records when they are completed and all appropriate

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information and signatures have been entered and paragraph 3.6 defines

interim storage as.the storage or safekeeping of records from the time

they are completed until submitted to project files for final. retention.

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N0P-003, paragraph 5.3.1,. states, " Interim storage of completed records

shall be in lockable, 1-hour rated, fireproof. file cabinets or access

- shall be controlled when the records are not in locked cabinets." The

failure to properly store and protect lifetime QA records associated with

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radioactive waste shipments made during 1986 to the present is an apparent

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violation of Technical Specification 6.8.1. (382/8706-01) P

5. Unresolved Item

86740, Item 02.05 - Procurement and Selection of Packaging

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An unresolved item is a matter about which additional information is

C needed for determination whether the item is acceptable, a violation, or a

deviation. One unresolved item is discussed below.

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10 CFR Dart 71.12(c)(3) requires that a licensee " submit in writing to the

Director, Office of Nuclear Material Safety and-Safeguards, prior to the

licensee's first use of a certified package, the licensee's name and.

license number and the package identification number specified in the

package approval." The NRC inspector determined that the licensee had

used two' certified packages (NUS-14-1701, USA /9151/A, and CNS-14-170,

USA /9079/A) in performing radwaste material shipments during 1986. The

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licensee was determined to be a licensed user of these packages according

to the user's lists for each of the above identified packages listed in

NUREG-0383, Volume 1, Revision 9, dated October 1986. However, the

licensee was unable to locate copies of the. license application and the

NRC approval letter licensing LP&L as a licensed user of the above

identified packages. This item will be considered unresolved pending

location of copies of the license application and the NRC license approval

to use the above identified packages. (382/8706-02)

6. Exit Briefing

The NRC inspector met with the licensee representatives denoted in

paragraph 1 at the conclusion of the inspection on March 27, 1987. The

NRC inspector summarized the scope of the inspection'and discussed the

inspection findings.