ML20128J969

Responds to NRC Re Violations Noted in Insp Rept 50-334/84-31.Corrective Actions:Current Procedures & Practices Reviewed to Determine Changes to QC Program & Future Audits Will Assess Compliance W/Qa Program

ML20128J969
Person / Time
Site:	Beaver Valley
Issue date:	04/08/1985
From:	Carey J DUQUESNE LIGHT CO.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20128J934	List: IR 05000334/1984031 ML20128J969
References
NUDOCS 8505310056
Download: ML20128J969 (4)

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Shippingport.PA 15077 0004 April 8, 1985

f. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Attn: Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs Region 1 631 Park Avenue King of Prussia, PA 19406

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 84-31 Gentlemen:

In' response to your letter of March 11, 1985, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced report.

If you have any questions concerning this response, please contact my office.

Very truly yours,

. arey 08 i e Presidebit, Nuclear Attachment cc: Mr. If. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261

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J DUQUESNE LIGHT COMPANY-Beaver Valley Power Station ,

Unit No. 1 Reply to Notice of Violation Inspection 84-31 Letter dated March 11, 1985 VIOLATION 1 (Severity Level IV; Supplement IV)

Description of Violation (84-31-04) 10 CFR 20.311(d)(3), " Transfer for disposal and manifests", requires the licensee to " conduct a quality control program to assure compliance with 61.55 and 61.56 of this chapter"...

10 CFR 61.55 and 61.56 requires, in part, that solid waste shall not contain free standing liquid greater than 1% of the waste volume, and the waste be properly classified and have structural stability.

Contrary to the above, on October 29, 1984, the licensee shipped 17.5 Curies of solidified licensed material to a waste burial site and the licensee did not conduct a quality control program to assure that the package did not contain free standing liquids greater than 1% of the waste volume; that the waste was. properly classified; and that the waste was structurally stable.

Corrective Action Taken A review of current procedures and practices was performed to determine what changes to our program may be necessary. While no problems were identified with the radwaste shipments, it appears that our program could be strengthened by modifying our procedures to better delineate the controls and verifications currently being used and to include additional quality control practices.

The BVPS Operating Manual, Chapter 18, " Solid Waste Disposal System" will be revised to provide for QC inspections to assure that packages do not contain free standing liquids greater than 1% of the waste volume and to verify the stability of the waste form. Radcon procedure RP 3.31, " Determination of Radioactive Waste Class" will be revised to provide for verification that the waste was properly classified, performed by radiation control personnel who are organizationally independent from those who perform the original waste classification calculations.

Action Taken to Prevent Recurrence The procedural by future chang (es discussed above and the increased assessment providedas d QA audits an adequate quality control program to assure compliance with 10 CFR 61.55 and 61.56.

Date on Which Full Compliance Will be Achieved The procedure changes discussed above will be implemented prior to June 1, 1985.

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Reply to Notice of Violation Inspection 84-31 Letter dated March 11, 1985 Page 2 VIOLATION 2 (Severity Level ~IV, Supplement IV)

Description of Violation (84-31-02) 10CFR71.101(b) " Quality Assurance Requirements", requires that chch licensee shall establish, maintain, and execute a Quality Assurance Program for trans-port packages satisfying each of the applicable criteria of this subpart. 10 CFR 71.101(f) states, a Commission-approved Quality Assurance Program which satisfied the applicable criteria of Appendix B of Part 50 of this chapter and which is established, maintained, and executed with regard to transport packages will be accepted as satisfying the requirements of paragraph (b) of this section.

A Commission approved QA Program pursuant to 10CFR50, Appendix B, was adopted as applicable to transport packages.

Criterion XVII, " Audits", of Appendix B, Part 50 requires that a comprehensive system of planned and periodic audits shall be carried out to verify compli-ance with all aspects of the Quality Assurance Program for transport packages and to determine the effectiveness of the program.

Contrary to the above, during 1983 and 1984 the licensee has not performed a comprehensive system of planned and periodic audits to verify compliance with applicable criteria of the Quality Assurance Program for transport packages, such as Criteria I, II, IV, X, XII, and XVII.

The two audits performed during 1983 and 1984 were only confined to Criteri-on V, " Instructions, Procedures, and Drawings".

Corrective Action Taken A review and evaluation was conducted on previous Solid Waste / Transportation Audits. The results indicate that prior audits attempted to assess the overall adequacy of the Radiological Waste Program but did not address all 10CFR criteria regarding transport packages. Future audits commencing with the second quarter 1985 Solid Waste / Transportation audit will assess compli-ance with applicable criteria of the Quality Assurance Program for transport packages as identified in NRC Inspection 84-31.

These audits will address items such as:

1. The organization of the Radiological Control Group is such that they can adequately and effectively administer the Solid Waste / Transport Program in accordance with 10CFR61. (Criterion 1)

2. The independent review of classification of waste and form of waste.

(Criterion II)

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e _ Reply to Notice of. Violation Insp:ction 84-31 LLetter dated March 11, 1985-

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3. . The review of. procurement documents with respect to the material and services of waste disposal contractor (s). (CriterionIV) 4 The = review of inspections performed. in compliance with 10CFR20.311(d)(3).'(Criterion'X) 5.- Evaluate the system 'in 'use for' controlling measuring' and . test -.

equipment.'(CriterionXII) 6.. The' review of documentation resulting -from administration Lof = the Solid Waste Management; Program. (Criterion XVII).

Action Taken to Prevent Recurrence Preparation for. future Solid Waste / Transportation Audits will include a review

. of appropriate 10CFR requirements to assure inclusion of applicable . criteria.

in the Audit Scope.

~ Date-on Which Full Compliance will be Achieved As. stated-above', the audit, BV-1-85-08, of Solid Waste / Transport- will be in compliance with the cited requirements.

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