IR 05000213/1986004: Difference between revisions

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{{Adams
{{Adams
| number = ML20216F832
| number = ML20140J472
| issue date = 06/18/1987
| issue date = 03/27/1986
| title = Ack Receipt of 870515 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/86-06, 50-336/86-06 & 50-213/86-04.Progress & Established Milestones for Training Program Noted
| title = Insp Rept 50-213/86-04 on 860310-14.Violation Noted:Failure to Provide Quantitative or Qualitative Acceptance Criteria, to Identify Radionuclide Quantity,Identity & Total Activity on Waste Manifests & Improper Certification
| author name = Martin T
| author name = Bicehouse H, Pasciak W
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name = Mroczka E
| addressee name =  
| addressee affiliation = NORTHEAST NUCLEAR ENERGY CO.
| addressee affiliation =  
| docket = 05000000, 05000213, 05000245, 05000336
| docket = 05000213
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8706300955
| document report number = 50-213-86-04, 50-213-86-4, IEB-79-19, NUDOCS 8604040341
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| package number = ML20140J454
| page count = 2
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 14
}}
}}


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U.S. NUCLEAR REGULATORY COMMISSION
,  JUN 18 1987 Docket Nos. 50-245 50-336 50-213
      ;
Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
Subject: Inspection Nos. 50-245/86-06, 50-336/86-06 and 50-213/86-04 We have reviewed your letter dated May 15, 1987, in response to our request for updates on your program improvement plan for your radwaste preparation, !
packaging and shipping progra We have noted your progress and the established milestones in your training program scheduled for complete implementation by December 31, 198 !
Thank you for informing us of the corrective and preventive actions documented in your lette These actions will be examined during a future inspection of your licensed progra Your cooperation with us is appreciate


Sincerely, original SiEDSU p as T. Martin, DiYector
==REGION I==
  -
Report No.
Division of Radiation Safety and Safeguards cc:
W. D. Romberg, Vice President, Nuclear Operations  !
S. E. Scace, Station Superintendent D, O. Nordquist, Manager of Quality Assurance R. M. Kacich, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut 0FFICIAL RECORD COPY RL MILLSTONE 86-06 - 0001. /13/87  f i 8706300955 DR 070618    !
ADOCK0500g3    jl (ht/ ,


      )
50-213/86-04 Docket No.
 
50-213 License No. DPR-61 Priority --
Category C Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Power Station Inspection At:
Haddam Neck, Connecticut l
Inspection Conducted: March 10-14, 1986 Inspectors:
Ao [
fe
.3 T7
[,
H.J. Bicehouse, Ra Wati&n Specialist dat e Approved by:
[A).
 
Mf[
3\\11 f(
iC Pasciak, Chief
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      :
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,. Northeast Utilities  -2-   l bec:
date Effluents Radiation Protection Section Inspection Summary:
Region I Docket Room (with concurrences)
Inspection March 10-14, 1986, (Report No. 50-213/86-04)
Management Assistant, DRMA (w/o enc 1)
Areas Inspected:
DRP Section Chief M. McBride, RI, Pilgrim P. Swetland, SRI, Haddam Neck J. Shedlosky, SRI, Millstone 3 M. Boyle, LPM, NRR R. Bores, DRSS i
Routine unannounced safety inspection by a regionally-based inspector of the licensee's radioactive waste preparation, packaging'and shipping program including: previously identified items, management controls, quality assurance / quality control and implementation of the program.
      \
 
      !
Results:
      !
Four apparent violations were identified (all relating to omissions of Iron-55 in shipment documents) including failure to provide quantitative or qualitative acceptance criteria (Detail 4.2), failure to indicate the radio-nuclide identity, quantity and total activity on waste manifests (Detail 6.1),
      ,
improper certification on waste manifests (Detail 6.1), and failure to name Iron-55 and include its activity on shipping papers (Detail 6.4).
 
B604040341 860327 DR ADOCK O
 
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DETAILS
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1.0 Personnel Contacted 1.1 Licensee Personnel
*R. H. Graves, Station Superintendent
*J. E. Beauchamp, QA/QC Supervisor
*G. H. Bouchard, Station Services Superintendent
*H. Clow, Health Physics Supervisor
*R. E. Haight, Radioactive Material Handling Supervisor
*W. Heinig, Quality Assurance Engineering Specialist
*J. J. LaPlatney, Station Services Staff Assistant Other licensee personnel were contacted or interviewed during this inspection.
 
1.2 NRC Personnel
* P. D. Swetland, Senior Re~sident Inspector
*S. M. Pindale, Resident Inspector
* Attended the exit interview on March 14, 1986.
 
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2.0~ Purpose The purpose of this routine safety inspection was to review the licensee's program with respect to the following areas:
=Previously Identified Items;
* Management Controls;
* Quality Assurance (QA)/ Quality Control (QC); and
* Implementation of the Radwaste Preparation, Packaging and Shipping Program.
i 3.0 Status of Previously Identified Items 3.1 (Closed) Unresolved (50-213/83-02-01) Audit not done. The annual audit for radwaste shipments (Audit No. A-60197, "Radwaste Shipment")
~
was completed in November 1983. This item is closed.
3.2 (Closed) Violation (50-213/84-11-01) Failure to follow procedures.
The licensee's actions (as described in the letter from J. F. Opeka, Vice President to T. T. Martin, NRC-Region I, dated 09/05/84) were reviewed.
Receipt inspections of High Integrity Containers (HIC)
were performed on a sample of those containers reviewed during the inspection. The licensee appeared to be implementing actions as
:
described in the licensee's letter.
This item is close.
'
3.3 (Closed) Violation (50-213/84-11-02) Failure to conduct a QC Program regarding 10 CFR 20.311(d)(3). The licensee's actions (described in the 9/5/84 letter) were reviewed. Additional actions (including hold points in waste processing procedures) have'been implemented.
This item is closed.
3.4 (Closed) Deviation (50-213/84-11-03) Failure to document training regarding IE Bulletin No. 79-19. Documentation of training on radioactive waste shipping, packaging and transportation was reviewed by the Resident. Inspector and appeared to be adequate. A formal program (described in Detail 4.3) has been developed and implemented. This item is closed.
3.5 (Closed) Followup Item (50-213/85-09-01) Failure to adequately train QC Inspectors. The licensee presented a course on radwaste preparation, packaging and shipping requirements to QC inspectors in December 1985. This item is closed.
3.5 (Closed). Followup Item (50-213/85-09-02) Failure to identify Package 14-170 as an unapproved package designation.
Licensee procedures and records were reviewed to determine if corrective actions ensured that shipping package designation corresponded to Certificate of Compliance (CoC) designations prior to shipment. The licensee appeared to have instituted adequate controls and quality control checks to ensure that shipping documents accurately reflected proper shipping container designations. This item is closed.
3.7 (Closed) Followup Item (50-213/85-09-03) Lack of QC involvement in 10 CFR 61.55 and 61.56.
Licensee procedures and records related to vendor-supplied radwaste solidification services were reviewed. QC inspection hold points (at appropriate steps in the procedure) were provided in the eight procedures reviewed and records indicated that QC inspections were completed at those holdpoints. This item is closed.
3.8 (Closed) Violation (50-213/85-09-04) Failure'to follow procedures for receipt inspections and failure to review / approve procedures.
Actions described in the licensee's letter (dated July 26, 1985) were reviewed. The licensee modified receipt procedures to ensure that appropriate QC inspections were performed. Vendor procedures governing operation and process control of radwaste solidification units were reviewed and approved as controlled plant procedures.
Review of records related to receipt of vendor-supplied solidifica-tion equipment showed that receipt inspections had been performed.
This item is close.
'
3.9 (0 pen) Followup Item (50-213/85-09-04) QA Procedures will be revised to reflect QA Topical Report. A draft corporate procedure, (i.e.
Nuclear Engineering and Operations Procedure 6.07, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification Packaging and Transportation"), was reviewed and it appeared to be generally adequate to address concerns raised in this item.
However, the procedure had not been approved and implemented at the time of the inspection. This item will remain open pending final revision, approval and implementation of the' procedure.
3.10 (Closed) Followup Item (50-213/85-09-06) Review QA monitoring
,
frequencies. The applications of QA monitoring procedures to the radwaste transportation area were reviewed and discussed with the licensee's QA organization.
The inspector noted that the frequency of QA monitoring in the area had not increased. However, increased QA surveillance activities were noted.
The licensee appeared to be reviewing procedural adherence by the radwaste shipping and QC groups on a more frequent basis (i.e. approximately once per quarter). This item is closed.
3.11 (Closed) Followup. Item (50-213/85-09-07) Review RWTRG Report. The licensee's Radioactive Waste Transportation Review Group (RWTRG)
Report, action items and their completion were reviewed. The licensee appeared to have adopted suggested corrective actions in the RWTRG Report.
This item is closed.
3.12 (Closed) Followup Item (50-213/85-09-08) Review Administrative Control Procedure (ACP) 1.2-13.5 for inclusion of correct sections
4 of Procedure RAP 6.3-5.
ACP 1.2-13.5, " Entry and Exit From Station of Transporter for Nuclear By-Products Material (Rad Waste),"
Revision 10 (10/18/85) was reviewed and determined to contain correct references to implementing procedures. This item is closed.
;
3.13 (Closed) Followup Item (50-213/85-09-09) Scaling factors were not controlled.
Radiation Protection Procedure (RAP) 6.3-5,
" Radioactive Material Management," Revision 27 (12/26/85)
was reviewed to determine if scaling factors for difficult to measure radionuclides from the licensee's vendor analysis of radwaste streams had been included. Attachment W to the procedure provided the 1985 scaling factors. This item is closed.
3.14 (Closed) Followup Item (50-213/85-09-10) Licensee did not maintain record of calculations.
In the licensee's letter (dated 7/26/85),
the licensee committed to maintaining a file for calculations utiliz-ing dose rate to curie conversion factors. The licensee had established a file containing memoranda from the licensee's corporate Radiological Assessment Branch (RAB) providing dose rate to curie conversion factors. However, the file did not contain the actual
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calculations'for the radwaste shipments covered by the RAB memoranda (see related item, Detail-6.1).
This item is closed administra-tively.
3.15 (Closed) Followup Item (50-213/85-09-11) Lack of administrative
,
controls to prevent' shipments. Surveillance Procedure (SUR) 5.6-14, (" Sampling Guidelines for~10 CFR 61 Compliance, Revision 4, 3/6/86");
was reviewed. Guidance was provided in the surveillance procedure to evoke recharacterization of waste streams if significant (i.e.
factor of 10 or more) changes in reactor coolant activity were noted.
This item is closed.
4.0 Management Controls The licensee's management controls were reviewed to determine if clear designations of responsibilities and controlled instructions were provided for radwaste processing, packaging and shipping activities.
Criteria provided in the licensee's Technical Specifications, Updated Final Safety Analysis Report and NRC Regulations were used in this review.
4.1 Organization The organizational structure of the licensee's Radioactive Materials Handling _(RMH) group was reviewed. The RMH group (in the Radiation Protection Department) is supervised by the RMH Supervisor. The RMH Supervisor reports to the Radiation Protection Supervisor who in turn reports to the Health Physics Supervisor. The responsibilities of the RMH group were clearly described in RAP 6.3-5 with regards to receipt, use, storage, packaging, loading and shipping solid radwaste.
Within the scope of this review, no violations were noted.
4.2 Procedures The licensee's procedures for preparation, classification, packaging and shipping radwastes were reviewed relative to criteria provided in:
-
10 CFR 20.311, 71.5 and 71.12; Technical Specification'6.8, " Procedures;"
-
-
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures and Drawings;"
-
NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)";-and
,
.
'
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ANSI N18.7-1976, " Administrative Controls and Quality Assurance for The Operational Phase of Nuclear Power Plants."
The following procedures were reviewed for conformance to the criteria above and discussed with the members of the RMH Group:
-
ACP 1.2-13.5, " Entry and Exit from Station of Transporter for Nuclear By-Products Material (Rad Waste)", Revision 10 (10/18/85);
-
RAP 6.3-5, " Radioactive Material Management," Revision 27 (12/26/85);
-
RAP 6.3-9, "Use of USNRC Certified Radioactive Material Packages," Revision 2 (10/24/85); and
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SUR 5.6-14, " Sampling Guidelines for 10 CFR Part 61 Compliance," Revision 4,(3/16/86).
Within the scope of this review, the following violation was noted:
10 CFR 50, Appendix B, Criterion V requires, in part, that procedures include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to this requirement, neither ACP 1.2-13.5 nor RAP 6.3-5 provides quantitative or qualitative acceptance criteria for verification of the identity of the radionuclides and activity levels (i.e. curie content) of the solid radwaste shipments.
Determining the identity of the radionuclides is an important activity since the identification affects determination of the acceptability of radwaste for disposal in shallow land burial sites under 10 CFR 20.311 and 10 CFR 61 and the packaging and handling of radwaste shipments under 10 CFR 71. Determining the curie content of solid radwaste shipments is also an important activity since it, too, affects the determination of the acceptability of the radwaste and its packaging'and handling requirements.
(See related item in Detail 6).
Failure to provide quantitative or qualitative acceptance criteria for the verification of the identity and curie content of radwaste shipments constitutes an apparent violation of 10 CFR 50, Appendix.B, Criterion V.
50-213/86-04-01 4.3 Indoctrination and Training The licensee's indoctrination and training program related to solid radwaste preparation, packaging and shipping activities was reviewed relative to criteria and commitments provided in the following:
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Technical Specification 6.3, " Facility Staff Qualifications;"
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c
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Technical Specification 6.4, " Training;"
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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel;"
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Licensee's letter W. G. Counsil to B._ H. Grier (NRC Region I)
dated 9/17/79 in response to IE Bulletin No. 79-19,
" Packaging of Low-Level Radioactive Waste for Transport and-Burial," (8/10/79); and
-
10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program."
The schedules, lesson plans and performance of the training was reviewed for' selected members of the RMH Group and QC personnel.
The licensee provided training inhouse and vendor-supplied training on alternate years for the personnel reviewed. Within the scope of this review, no violations or deviations were noted.
5.0 _ Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a QA program for the packaging and transportation of radioactive materials. A Commission approved QA program which satisfies the applicable criteria of Appendix 8 to 10 CFR 50 and which is established, maintained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.
The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radioactive materials.
Specific QC requirements to assure compliance with 10 CFR 61.55 and 61.56 are mandated by 10 CFR 20.311 in addition to the general QC requirements required by 10 CFR 50, Appendix B.
A process control program for. waste solidification is required by Technical Specification 6.18, " Radioactive Waste Treatment Systems." The implementation of QA/QC activities to the preparation, packaging and shipment of solid radwaste was reviewed.
5.1 Radwaste Generator QC Program The licensee's performance in the conduct of a QC program under 10 CFR 20.311(d)(3) and Technical Specification 6.18 was determined by review of procedures for preparing radwaste shipments, examination of records related to shipments of dewatered resins, solidified waste liquids and dewatered filters, independent determination of waste classification under 10 CFR 61.55 for selected shipments and discussions with the RMH Supervisor, members of the RMH Group staff, solidification vendor representatives and the QA/QC supervisor.
Within the scope of this review, the following items were noted:
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Samples from the licensee's dry active waste, resins, reactor coolant, evaporator bottoms and filters were taken and sent to a contractor for analysis.
Scaling factors for determining the activities of difficult to measure radionuclides were determined by the contractor and provided in annual reports.
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The vendor's Process Control Program for solidification of waste liquids was reviewed, incorporated into licensee's procedures and implemented.
Specific Inspection Hold Points related to dewatering and/or
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solidification were provided in controlled procedures.
5.2 QC Inspection Activities The site QC organization provides inspections of radwaste preparation, packaging and shipping activities. The following procedures were reviewed for appropriate inspection hold points:
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RAP 6.3-5, " Radioactive Material Management," Revision 27 (12/26/85);
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RAP 6.3-9, "Use of USNRC Certified Radioactive Material Packages," Revision 2 (10/24/85);
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Vendor Procedure SS-001, " Process Control Program for NUSPSC Radwaste solidification Systems," Revision I (8/16/85);
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Vendor Procedure SS-008, " Operating Procedure for NUSPSC Radwaste Solidification System No. 8921," Revision D (3/11/85);
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Vendor Procedure SS-010, " System Setup / Removal Procedure for NUSPSC Radwaste Solidification System No. 8921," Revision B (10/3/84);
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Vendor Procedure SS-013, " Operating Procedure for NUSPSC Radwaste Solidification System No. 8901," Revision B (5/22/85);
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Vendor Procedure SS-014, " Process Control Program for NUSPSC Radwaste Solidification Systems - Class A, Unstable Wastes,"
Revision C (5/23/85);
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Vendor Procedures SS-015, " System Setup / Removal Procedure for NUSPSC Radwaste Solidification System No. 8901," Revision A
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(2/12/85);
Vendor Procedure SS-022, " Operating Procedure for NUSPSC
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Radwaste Solidification System No. 8807," Revision A (11/16/85); and
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Verdor Procedure SS-021, " System Setup / Removal Procedure for
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NUSPSC Radwaste Solidification System No. 8807," Revision A (11/16/85).
Representatives of the site QC organization were interviewed to-determine the criteria by which successful completion of selected Inspection Hold Points was determined. The inspector noted that the site QC organization did not independently verify that the identity and activities of the various radionuclides in the shipping papers vere correct. The inspector also noted that peer review by qualified members of the Radiation Protection staff of the identities and activities of the shipped radionuclides wasn't routinely completed.
5.3 QA Surveillance Activities The site QA organization provides periodic surveillance of solid radwaste preparation, packaging and shipping activities. As noted in Detail 3.10, surveillance frequencies had been increased by the licensee. However, QA surveillance activities did not include independent verification of the identities and activities of the radionuclides as presented in the shipping. papers.
5.4 Audits The licensee's program for audits of radwaste. preparation, classification, packaging and shipping activities was reviewed.
Audit No. A60221 "Radwaste Shipment at Connecticut Yankee Power Station," (3/20 - 6/6/85) was reviewed. The audit was performed to verify the station's implementation of 10 CFR 20, 61, 71 and 49 CFR requirements. The audit was conducted by two QA auditors and a qualified technical specialist. The inspector noted that audit findings had been evaluated by licensee management (as required by 10 CFR 20.311(d)(3)).
The audit failed to note the problem with Iron-55 identification and quantification in shipping and waste manifests (See Detail 6).
.6.0 Impiementation During 1985-86, the licensee made 29 shipments of solid radwaste. Those radwaste shipments were reviewed against criteria provided in:
10 CFR 20.311, 61.55 and 61.56;
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10 CFR 71;
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49 CFR 170-189; and Station Technical Specifications and Procedures.
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The Itcansee reported that the Agreement State in which the radwaste shipments were buried had not issued any violations or warnings for the radwaste shipments received.


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6.1 Vaste Generator Requirements The following waste generator requirements were reviewed and discussed with the licensee:
      )
Waste Panifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);
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. . s D SS:RI DRSS:RI D S :Ri Bicehouse/k1 Pasciak Bellamy  '
Waste Classification under 10 CFR 20.311(d)(1);
6/faf/87 6/l@/87 6/ /1 /87 0FFICIAL RECORD COPY RL MILLSTONE 86-06 - 0002. /13/87
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Waste form and Characterization under 10 CFR 20.311(d)(1) and
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10 CFR 61.56; Waste shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR
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61.55; Tracking of waste shipments under 10 CFR 20.311(d), (e), (f)
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and (b); and Disposal site license conditions.


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Within the scope of this review, the following violations were noted:
10 CFR 20.311(b)' requires, in part, that the manifest
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accompanying radwaste shipments indicate as completely as practicable the radionuclide identity and quantity and the total radioactivity of the shipments.


.       !
Contrary to this requirement, the licensee failed to identify the radionuclide Iron-55 and its activity on the following radwaste shipment manifests:
Total Listed Activity Shipment No.
 
Descript (curies)
Date W-85-1 Dewatered resin 3.332 3/5/85 W-85-2 Dewatered filters 7,599 5/14/85 W-85-3 Cewatered filters 19.18 5/28/85 W-85-5 Compacted dry 0.747 2/20/85 activ'e waste W-85-8 Solidified ligulds 1.123 10/4/85 W-85-9 Dewatered resin 8.783 10/22/85 W-85-10 Compacted dry 0,6319 10/10/85 active waste W-85-11 Solidified liquids 0.1161 8/28/85 W-85-12 Dewatered resins 134.49 9/18/85 W-85-13 Solidified liquids 3.978 10/4/85 W-85-15 Solidified liquids 1.460 10/25/85 W-85-18 Dewatered resin 16.061 12/30/85
 
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General ottices * Seiden Street. Berhn. Connecticut 9 if ,UEIcNi$iNU.'.'
k ' J .w
  .I. N.o7 co. . .
  .$ch.,
co- g P o. BOX 270 HARTFORD. CONNECTICUT 061410270 (203) 665 5000
    .
May 15, 1987 Docket Nos. 50-245 50-336 A05929 Re: 10CFR71 U.S. Nuclear Regulatory Commission Attn Document Control Desk      l
        '
washington, D.C. 20555 References: (1) E. Murley letter to F. Opeka, dated July 22, 1986, Inspection Report No. 50-245/86-06, 50-336/86-06 and 50-213/86-04, (2) F. Opeka letter to T. Murley, dated August 21,  i 1986, Response to Inspection No. 50-245/86-06, 50-  i 336/86-06 and 50-213/86-0 (3) F. Opeka letter to T. E. Murley, dated November 19, 1986, Update to Response to I&E Inspection N /86-06 and 50-336/86-0 (4) E. Mroczka letter to U.S. NRC, dated February 17, 1987, Update to Response to I& E Inspection No. 50-245/86-06 and 50-336/86-0 Gentlemen:      i,
        !
Millstone Nuclear Power Station, Units No. I and 2-Update to Response to I&E Inspection No. 50-245/86-06 and 50-336/-06  -
o Reference (1) informed Northeast Nuclear Energy Company (NNECO) of five Level IV violations, which were identified during inspections at the Millstone Nuclear Power Station, Units No. 1 and 2 (March 24-27, 1986). In addition to responding to the inspection report, Referenec (1)-directed that an update be provided every 90 days until all upg rades a re complete !
  / ' wy1 b
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i


      !
Total Listed Activity Shipment No.
. .
 
.
Descript (curies)
,
Date
    -2-Reference (2) responded to Reference (1).
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W-85-19 Dewatered resin.
 
2.192 12/20/85
.W-86-5 Solidified liquid 0.2041 2/13/86 W-86-6 Solidified liquid 5.305 2/25/86 W-86-8 Solidified liquid 1.741 3/11/86 W-86-9 Solidified liquid 2.5793 3/13/86 W-86-11 Solidified liquid 0.6091 2/10/86 The licensee's vendor analyses of various radwaste streams within the plant identified the presence of Iron-55 and provided the following scaling factors relative to cobalt-60 activity:
Waste Stream Analysed Iron-55/ Cobalt-60 ratio Reactor coolant-liquid 1.4 Resin 1.9 Filter 6.7 Dry active waste 1.5 Evaporator bottoms 1.3 The licensee determines the percent isotopic composition for the energetic gamma emitting radionuclides (e.g. cobalt-60) and a dose rate to curie conversion factor for the waste shipment container geometry based on gamma spectroscopic analysis and accepted computer programs. Calculations-of the activity of hard-to-identify radionuclides (e.g. Iron-55) are then made using the scaling factors provided in the vendor's analytical report.
 
For example, licensee's shipment no. W-85-12 contained 5.16%. cobalt-60 by gamma spectroscopic analysis. The scaling factor for Iron-55 in dewatered
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resins is 1.9.
 
The calculated total activity due to Iron-55 in the shipment would be found by multiplying the shipment's total activity by the fraction due to Cobalt-60 activity and the appropriate scaling factor, vis. (0.0516) (134.49 curies) (1.9) = 13.18 curies additional activity due to Iron-55. However, the licensee failed to list Iron-55 as a constituent'of the shipments listed above and did not conduct the calculations as shown above to determine the activity due to Iron-55 in each shipment.
 
The inspector calculated the estimated activity due to Iron-55 in each of shipments below:
Total Activity Percent Scaling Activity from Shipment No.
 
(Curies)
Cobalt-60 Factor Iron-55 (Curies)
W-85-1 3.332 71.5 1.9 4.52 W-85-2 7.599 11.0 6.7 5.60 W-85-3 19.18 13.3 6.7 17.09 W-85-5 0.747 24.1 1.5 0.27
 
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Total Activity. Percent Scaling Activity from Shipment No.
 
(Curies)
Cobalt-60 Factor Iron-55 (Curies)
l W-85-8 1.123 47.98 1.3 0.70 W-85-9 8.783 8.30 1.9 1.38 W-85-10 0.6319 28.8 1.5 0.27 W-85-11 0.1161 2.72 1.3 0'.004 W-85-12 134.49 5.16 1.9 13.18-W-85-13 3.978 57.27 1.3 2.96 W-85-15 1.460 12.03 1.3 0.22 W *5-13 16.061 0.294 1.9-0.0897 W-85-19 2.192 0.691 1.9 0.0287 W-86-5 0.2041 21.03 1.3 0.0558 W-86-6 5.305 14.26 1.3 0.983 W-86-8 1.741 23.34 1.3 0.528 W-86-9 2.5793 27.57 1.3 0.924 W-86-11 0.6091 15.17 1.3 0.120 Since Iron-55 was not identified and its activity determined for each shipment, the manifests accompanying each shipment contained
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incorrect total activities for those shipments.
 
Failure to identify Iron-55, determine its activity in each shipment and include the radionuclide in the total radioactivity of.the shipment constitutes an apparent violation of 10 CFR 20.311(b).
 
50-213/86-04-02
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10 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly described. Contrary to this requirement, the licensee certified that each of the radwaste shipments above were properly described when the identity of one of the radionuclides was missing and the activity due to that radionuclide was not identified and included in the total activity of the transported materials.
 
Certification that each of the waste shipments were' properly described when they were not constitutes an apparent violation of 10 CFR 20.311(c).
 
50-213/86-04-03 6.2 Procurement and Selection of Packaging The licensee's program for the selection of packages was reviewed against the requirements of 10 CFR 71.12, " General License: NRC Approved Package" and the Department of Transportation (00T)
requirements of.49 CFR 173, " Shippers - General Requirements for Shipments and Packaging."
 
The licensee's performance relative to the criteria was determined by interviews of the RMH Supervisor and members of his staff, examinations of documents, procedures and shipping records and observations during plant tours.
 
Within the scope of this review, no violations were note.-
*
 
6.3 Preparation of Packages for Shipment The licensee's program for preparing packages for shipment was reviewed relative to the requirements of 49 CFR Parts 172 and 173, 10 CFR 71.87 and Technical Specifications.
 
The. licensee's performance relative to the criteria was determined by interviews of the RMH Supervisor and members of his staff, examination of procedures,~ shipping records and other documents, and observations during plant tours of handling, storage and loading areas and licensee preparations for shipment of a cask.
 
Within the scope of this review, the following item was noted:
On 9/11/85, the licensee was installing a high integr'ty container (HIC) in the " Resin Pit" area and connecting lines to the container for dewatering. An Auxiliary Operator, a Radwaste Technician and a Health Physics Technician were assigned to the operation working under Radiation Work Permit No. 8502183. The
" Resin Pit" area was a high radiation area with radiation fields ranging from 100 millirem per. hour to 18,000 millirem per hour in the work area. The fitting on the HIC for the dewatering leg was a 2 inch fitting while the line used for_the dewatering contained a lh inch fitting. The Radwaste Technician was unable to make the connections for the dewatering and remained in the high radiation area attempting to connect the 2 inch fitting to the 1h inch line.
 
The low-range, (i.e. 0-200 millirem), dosimeter for the Radwaste Technician was noted to be "offscale".
 
Examination of his high range dosimeter indicated an exposure of approximately 950 millirems during the Radwaste Technician's attempts to connect the dewatering line.
 
The licensee's investigation and resolution of the problems encountered during the entry were reviewed. This area will be further reviewed during a subsequent inspection. 50-213/86-04-05 6.4 Delivery of Packages to Carriers The licensee's program for delivering packages to carriers was reviewed relative to criteria provided in:
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10 CFR 71.5 (a) (1) (iii), " Placarding;"
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10 CFR 71.5 (a) (1) (vi), " Shipping Manifests:d 10 CFR 71.5 (a) (1) (iv), "Public Highway - 49 CFR Part 177;"
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and licensee's Technical Specifications.and applicable procedures.
 
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The licensee's performance relative to the criteria was determined by review of shipping records for radwaste shipments in 1985-86, discussions with cognizant licensee personnel and ubservation of preparations for a radwaste shipment.
 
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Within the scope of this review, the following apparent violation was noted:
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10 CFR 71.5(a)(1)(vi) requires preparation of shipping papers in accordance with 49 CFR 172, Subpart C.
 
49 CFR 172.203(d)(i)
requires the name of each radionuclide in the shipment and 49 CFR 172.203(d)(iii) requires the activity of each package in the shipment be included in the shipping papers.
 
Contrary to the requirements, the licensee failed to include Iron-55 and the activity resulting from that radionuclide in the shipping papers associated with the radwaste shipments in Detail 6.1.
 
Failure to name Iron-55 and include the activity due to that radionuclide in the shipping papers associated with the radwaste shipments in Detail 6.1 constitutes an apparent violation of 10 CFR 71.5 (a) (1) (vi). 50-213/86-04-04 7.0 Exit Interview
,
The inspector met with the licensee representativeshenojed,in i
Paragraph 1) at the conclusion of the inspection on Kirch 14,4986. The inspector summarized the scope of the inspection and findings asu
,
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described in this report.


provided the 90-day updates. This report isReferences (3) and (4)
The licensee's representative acknowledged the findings r' elated to the omission of Iron-55 in the waste manifests and shipping papers and provided the following corrective actions in response to the finding:
    'the third 90-day update and provides the status on all items that were incomplete as of the date of our Reference (4) updat Alleged Vi'olation 10 CFR 71.5 requires that each licensee who transports . license material outside of the confines of its plant and other place of use, or who delivers licensed material to a carrier for transport, shall comply with the. applicable requirements of the regulations appropriate to the mode of . transport of _ DOT in 49 CPR Parts 170 through 18 CFR 172.403(c) requires, in part, that a Radioactive Ye llow -III label must be affixed.to each. package of. radioactive material which '
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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 j
Before the next radwaste shipment, the licensee will audit radwaste shipments 1984-86 to determine which shipments had incorrect' waste manifests and shipping papers due to the omisstor, of Iron-55.
that a vehicle contains packages of licensed material that are labeled Radioactive Yellow-III .
      '
l Contrary.to the above, on March 5, 1986, licensed material was delivered to a carrier for transport in a package which had a radiation. level of 3.0 millirem per hour at 1 meter from the surface of the package, 'and this package was erroneously labeled 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).
,
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Before the next radwaste shipment, the licensee will notify the DOT and the State of South Carolina of the results of the audit.


270 Day Status Development of the training program is continuing . The task analysis for.Radwaste personnel was completed on schedule in February, 198 Also,
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. instructional objectives were generated by Nuclear Training and approved by the Training Prog ram Control Commi ttee for Radwas te in March, 198 A performance based continuing training prog ram consisting of class-room and on-the-job-training will be developed by July 30, 1987 and completely implemented by December 31, 198 !
Before the next radwaste shipment, the licensee will revise RAP
      ,
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A l_IJtigd Vi ola t i on 10 CPR 50, Appendix B, Criterion II requires, in part, that the licensee shall provide for indoctrination and training of personnel performing activities af fecting quality as necessary to assure that suitable proficiency is achieved and maintained.
6.3-5 to include Iron-55 and to require an independent review of the identities and activities associated with each shipment.


I
The licensee will provide corrected waste manifests and shipping
      :
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      }
papers to the DOT and the State of South Carolina.


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The' licensee will update the Semiannual Radioactive Effluent and Waste Disposal Reports to include activities due to Iron-55.
      )
  -3-
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Contrary to the above, as of March 27, 1986, the Acting Radioactive Materials Handling Supervisor and the principal Radioactive Waste l
Materials Handler, who are involved in an activity affecting quality i in the handling of radioactive materials, were not adequately trained ,
to assure that suitable proficiency was achieved and maintaine 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- i 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 complexity of these regulations and of the complexity of the transportation activities at the Millstone Nuclear Power Statio This is a _ Severity Level IV violation (Supplement V).


270 Day Status Development of the training program is continuing. The task analysis for-Radwaste personnel was completed on schedule in February, 198 Also, instructional objectives were generated by Nuclear Training and approved by the Training Program Control Committee for Radwaste in March, 198 A performance based continuing training program consisting of classroom and on-the-job-training will be developed by July 30, 1987 and completely implemented by December 31, 198 Day Status of Improvements to Radioactive Materials Depa r tme n t l The Radiation Protection Supervisor attended the Waste Management Conference in Arizona, and the Assistant Radiation Protection Supervisor attended the Chem Nuclear Training on Transportation and Packaging of Radioactive Materia l
At no time during this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under
      \ Monthly surveillance of the processing of radioactive waste including packaging and shipping is continuing . Surveillances done during this time period are listed belo S686-01 Radwaste Shipping and Handling of Resins l
,
S686-03 Radwaste compliance to Procedure NEO 6.07, " Quality i Assurance and Quality Control in Station Radioactive Material Processing , Classification, Packaging, and i Transportation" i
10 CFR 2.790 is discussed in this report.
S687-01 Compacting waste  ,
S687-02 Shipping cask 8-120B air test S687-06 Laundry snipment LSA  !
i
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F
_
. -.
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l r
i I
.    -4-  -l Programs pursued andfor the reduction implemente of radioactive . waste are being actively j
      ! ACP-OA-2. 01B , "OA and OC In Station Radioactive Material I i
!
' Processing , Classification, Packaging and Transportation" was incorporated into ACP-0A-2.01A, " Radioactive Material and. Waste Pack ag i ng , Shipping and Processing Quality Assurance Program"..
This revision establishes the Quality Assurance requirements I governing the Radioactive Material Shipping Quality Assurance Program at the Millstone' Statio A status report of upgrades and improvements in our program for preparation, packaging and shipment of radioactive materials will be furnished to you every 90 days until- upgrades are complete {
Very truly yours,  >
NORTHEAST NUCLEAR ENERGY COMPANY t E. pi.''Mroczk3 M
Senior .Vice President
      !
cc: T.-Russell, Region I Administrator  l
      '
J.- Shea, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 Rebelowksi, Senior Resident Inspector, Millstone Unit Nos. I and 2 l
lI f
}}
}}

Latest revision as of 16:09, 11 December 2024

Insp Rept 50-213/86-04 on 860310-14.Violation Noted:Failure to Provide Quantitative or Qualitative Acceptance Criteria, to Identify Radionuclide Quantity,Identity & Total Activity on Waste Manifests & Improper Certification
ML20140J472
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 03/27/1986
From: Bicehouse H, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140J454 List:
References
50-213-86-04, 50-213-86-4, IEB-79-19, NUDOCS 8604040341
Download: ML20140J472 (14)
v • d • e


Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-213/86-04 Docket No.

50-213 License No. DPR-61 Priority --

Category C Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Power Station Inspection At:

Haddam Neck, Connecticut l

Inspection Conducted: March 10-14, 1986 Inspectors:

Ao [

fe

.3 T7

[,

H.J. Bicehouse, Ra Wati&n Specialist dat e Approved by:

[A).

Mf[

3\\11 f(

iC Pasciak, Chief

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date Effluents Radiation Protection Section Inspection Summary:

Inspection March 10-14, 1986, (Report No. 50-213/86-04)

Areas Inspected:

Routine unannounced safety inspection by a regionally-based inspector of the licensee's radioactive waste preparation, packaging'and shipping program including: previously identified items, management controls, quality assurance / quality control and implementation of the program.

Results:

Four apparent violations were identified (all relating to omissions of Iron-55 in shipment documents) including failure to provide quantitative or qualitative acceptance criteria (Detail 4.2), failure to indicate the radio-nuclide identity, quantity and total activity on waste manifests (Detail 6.1),

improper certification on waste manifests (Detail 6.1), and failure to name Iron-55 and include its activity on shipping papers (Detail 6.4).

B604040341 860327 DR ADOCK O

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DETAILS

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1.0 Personnel Contacted 1.1 Licensee Personnel

  • R. H. Graves, Station Superintendent
  • J. E. Beauchamp, QA/QC Supervisor
  • G. H. Bouchard, Station Services Superintendent
  • H. Clow, Health Physics Supervisor
  • R. E. Haight, Radioactive Material Handling Supervisor
  • W. Heinig, Quality Assurance Engineering Specialist
  • J. J. LaPlatney, Station Services Staff Assistant Other licensee personnel were contacted or interviewed during this inspection.

1.2 NRC Personnel

  • P. D. Swetland, Senior Re~sident Inspector
  • S. M. Pindale, Resident Inspector
  • Attended the exit interview on March 14, 1986.

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2.0~ Purpose The purpose of this routine safety inspection was to review the licensee's program with respect to the following areas:

=Previously Identified Items;

  • Management Controls;
  • Quality Assurance (QA)/ Quality Control (QC); and
  • Implementation of the Radwaste Preparation, Packaging and Shipping Program.

i 3.0 Status of Previously Identified Items 3.1 (Closed) Unresolved (50-213/83-02-01) Audit not done. The annual audit for radwaste shipments (Audit No. A-60197, "Radwaste Shipment")

~

was completed in November 1983. This item is closed.

3.2 (Closed) Violation (50-213/84-11-01) Failure to follow procedures.

The licensee's actions (as described in the letter from J. F. Opeka, Vice President to T. T. Martin, NRC-Region I, dated 09/05/84) were reviewed.

Receipt inspections of High Integrity Containers (HIC)

were performed on a sample of those containers reviewed during the inspection. The licensee appeared to be implementing actions as

described in the licensee's letter.

This item is close.

'

3.3 (Closed) Violation (50-213/84-11-02) Failure to conduct a QC Program regarding 10 CFR 20.311(d)(3). The licensee's actions (described in the 9/5/84 letter) were reviewed. Additional actions (including hold points in waste processing procedures) have'been implemented.

This item is closed.

3.4 (Closed) Deviation (50-213/84-11-03) Failure to document training regarding IE Bulletin No. 79-19. Documentation of training on radioactive waste shipping, packaging and transportation was reviewed by the Resident. Inspector and appeared to be adequate. A formal program (described in Detail 4.3) has been developed and implemented. This item is closed.

3.5 (Closed) Followup Item (50-213/85-09-01) Failure to adequately train QC Inspectors. The licensee presented a course on radwaste preparation, packaging and shipping requirements to QC inspectors in December 1985. This item is closed.

3.5 (Closed). Followup Item (50-213/85-09-02) Failure to identify Package 14-170 as an unapproved package designation.

Licensee procedures and records were reviewed to determine if corrective actions ensured that shipping package designation corresponded to Certificate of Compliance (CoC) designations prior to shipment. The licensee appeared to have instituted adequate controls and quality control checks to ensure that shipping documents accurately reflected proper shipping container designations. This item is closed.

3.7 (Closed) Followup Item (50-213/85-09-03) Lack of QC involvement in 10 CFR 61.55 and 61.56.

Licensee procedures and records related to vendor-supplied radwaste solidification services were reviewed. QC inspection hold points (at appropriate steps in the procedure) were provided in the eight procedures reviewed and records indicated that QC inspections were completed at those holdpoints. This item is closed.

3.8 (Closed) Violation (50-213/85-09-04) Failure'to follow procedures for receipt inspections and failure to review / approve procedures.

Actions described in the licensee's letter (dated July 26, 1985) were reviewed. The licensee modified receipt procedures to ensure that appropriate QC inspections were performed. Vendor procedures governing operation and process control of radwaste solidification units were reviewed and approved as controlled plant procedures.

Review of records related to receipt of vendor-supplied solidifica-tion equipment showed that receipt inspections had been performed.

This item is close.

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3.9 (0 pen) Followup Item (50-213/85-09-04) QA Procedures will be revised to reflect QA Topical Report. A draft corporate procedure, (i.e.

Nuclear Engineering and Operations Procedure 6.07, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification Packaging and Transportation"), was reviewed and it appeared to be generally adequate to address concerns raised in this item.

However, the procedure had not been approved and implemented at the time of the inspection. This item will remain open pending final revision, approval and implementation of the' procedure.

3.10 (Closed) Followup Item (50-213/85-09-06) Review QA monitoring

,

frequencies. The applications of QA monitoring procedures to the radwaste transportation area were reviewed and discussed with the licensee's QA organization.

The inspector noted that the frequency of QA monitoring in the area had not increased. However, increased QA surveillance activities were noted.

The licensee appeared to be reviewing procedural adherence by the radwaste shipping and QC groups on a more frequent basis (i.e. approximately once per quarter). This item is closed.

3.11 (Closed) Followup. Item (50-213/85-09-07) Review RWTRG Report. The licensee's Radioactive Waste Transportation Review Group (RWTRG)

Report, action items and their completion were reviewed. The licensee appeared to have adopted suggested corrective actions in the RWTRG Report.

This item is closed.

3.12 (Closed) Followup Item (50-213/85-09-08) Review Administrative Control Procedure (ACP) 1.2-13.5 for inclusion of correct sections

4 of Procedure RAP 6.3-5.

ACP 1.2-13.5, " Entry and Exit From Station of Transporter for Nuclear By-Products Material (Rad Waste),"

Revision 10 (10/18/85) was reviewed and determined to contain correct references to implementing procedures. This item is closed.

3.13 (Closed) Followup Item (50-213/85-09-09) Scaling factors were not controlled.

Radiation Protection Procedure (RAP) 6.3-5,

" Radioactive Material Management," Revision 27 (12/26/85)

was reviewed to determine if scaling factors for difficult to measure radionuclides from the licensee's vendor analysis of radwaste streams had been included. Attachment W to the procedure provided the 1985 scaling factors. This item is closed.

3.14 (Closed) Followup Item (50-213/85-09-10) Licensee did not maintain record of calculations.

In the licensee's letter (dated 7/26/85),

the licensee committed to maintaining a file for calculations utiliz-ing dose rate to curie conversion factors. The licensee had established a file containing memoranda from the licensee's corporate Radiological Assessment Branch (RAB) providing dose rate to curie conversion factors. However, the file did not contain the actual

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calculations'for the radwaste shipments covered by the RAB memoranda (see related item, Detail-6.1).

This item is closed administra-tively.

3.15 (Closed) Followup Item (50-213/85-09-11) Lack of administrative

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controls to prevent' shipments. Surveillance Procedure (SUR) 5.6-14, (" Sampling Guidelines for~10 CFR 61 Compliance, Revision 4, 3/6/86");

was reviewed. Guidance was provided in the surveillance procedure to evoke recharacterization of waste streams if significant (i.e.

factor of 10 or more) changes in reactor coolant activity were noted.

This item is closed.

4.0 Management Controls The licensee's management controls were reviewed to determine if clear designations of responsibilities and controlled instructions were provided for radwaste processing, packaging and shipping activities.

Criteria provided in the licensee's Technical Specifications, Updated Final Safety Analysis Report and NRC Regulations were used in this review.

4.1 Organization The organizational structure of the licensee's Radioactive Materials Handling _(RMH) group was reviewed. The RMH group (in the Radiation Protection Department) is supervised by the RMH Supervisor. The RMH Supervisor reports to the Radiation Protection Supervisor who in turn reports to the Health Physics Supervisor. The responsibilities of the RMH group were clearly described in RAP 6.3-5 with regards to receipt, use, storage, packaging, loading and shipping solid radwaste.

Within the scope of this review, no violations were noted.

4.2 Procedures The licensee's procedures for preparation, classification, packaging and shipping radwastes were reviewed relative to criteria provided in:

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10 CFR 20.311, 71.5 and 71.12; Technical Specification'6.8, " Procedures;"

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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures and Drawings;"

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NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)";-and

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ANSI N18.7-1976, " Administrative Controls and Quality Assurance for The Operational Phase of Nuclear Power Plants."

The following procedures were reviewed for conformance to the criteria above and discussed with the members of the RMH Group:

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ACP 1.2-13.5, " Entry and Exit from Station of Transporter for Nuclear By-Products Material (Rad Waste)", Revision 10 (10/18/85);

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RAP 6.3-5, " Radioactive Material Management," Revision 27 (12/26/85);

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RAP 6.3-9, "Use of USNRC Certified Radioactive Material Packages," Revision 2 (10/24/85); and

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SUR 5.6-14, " Sampling Guidelines for 10 CFR Part 61 Compliance," Revision 4,(3/16/86).

Within the scope of this review, the following violation was noted:

10 CFR 50, Appendix B, Criterion V requires, in part, that procedures include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to this requirement, neither ACP 1.2-13.5 nor RAP 6.3-5 provides quantitative or qualitative acceptance criteria for verification of the identity of the radionuclides and activity levels (i.e. curie content) of the solid radwaste shipments.

Determining the identity of the radionuclides is an important activity since the identification affects determination of the acceptability of radwaste for disposal in shallow land burial sites under 10 CFR 20.311 and 10 CFR 61 and the packaging and handling of radwaste shipments under 10 CFR 71. Determining the curie content of solid radwaste shipments is also an important activity since it, too, affects the determination of the acceptability of the radwaste and its packaging'and handling requirements.

(See related item in Detail 6).

Failure to provide quantitative or qualitative acceptance criteria for the verification of the identity and curie content of radwaste shipments constitutes an apparent violation of 10 CFR 50, Appendix.B, Criterion V.

50-213/86-04-01 4.3 Indoctrination and Training The licensee's indoctrination and training program related to solid radwaste preparation, packaging and shipping activities was reviewed relative to criteria and commitments provided in the following:

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Technical Specification 6.3, " Facility Staff Qualifications;"

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Technical Specification 6.4, " Training;"

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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel;"

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Licensee's letter W. G. Counsil to B._ H. Grier (NRC Region I)

dated 9/17/79 in response to IE Bulletin No. 79-19,

" Packaging of Low-Level Radioactive Waste for Transport and-Burial," (8/10/79); and

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10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program."

The schedules, lesson plans and performance of the training was reviewed for' selected members of the RMH Group and QC personnel.

The licensee provided training inhouse and vendor-supplied training on alternate years for the personnel reviewed. Within the scope of this review, no violations or deviations were noted.

5.0 _ Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a QA program for the packaging and transportation of radioactive materials. A Commission approved QA program which satisfies the applicable criteria of Appendix 8 to 10 CFR 50 and which is established, maintained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H.

The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radioactive materials.

Specific QC requirements to assure compliance with 10 CFR 61.55 and 61.56 are mandated by 10 CFR 20.311 in addition to the general QC requirements required by 10 CFR 50, Appendix B.

A process control program for. waste solidification is required by Technical Specification 6.18, " Radioactive Waste Treatment Systems." The implementation of QA/QC activities to the preparation, packaging and shipment of solid radwaste was reviewed.

5.1 Radwaste Generator QC Program The licensee's performance in the conduct of a QC program under 10 CFR 20.311(d)(3) and Technical Specification 6.18 was determined by review of procedures for preparing radwaste shipments, examination of records related to shipments of dewatered resins, solidified waste liquids and dewatered filters, independent determination of waste classification under 10 CFR 61.55 for selected shipments and discussions with the RMH Supervisor, members of the RMH Group staff, solidification vendor representatives and the QA/QC supervisor.

Within the scope of this review, the following items were noted:

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Samples from the licensee's dry active waste, resins, reactor coolant, evaporator bottoms and filters were taken and sent to a contractor for analysis.

Scaling factors for determining the activities of difficult to measure radionuclides were determined by the contractor and provided in annual reports.

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The vendor's Process Control Program for solidification of waste liquids was reviewed, incorporated into licensee's procedures and implemented.

Specific Inspection Hold Points related to dewatering and/or

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solidification were provided in controlled procedures.

5.2 QC Inspection Activities The site QC organization provides inspections of radwaste preparation, packaging and shipping activities. The following procedures were reviewed for appropriate inspection hold points:

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RAP 6.3-5, " Radioactive Material Management," Revision 27 (12/26/85);

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RAP 6.3-9, "Use of USNRC Certified Radioactive Material Packages," Revision 2 (10/24/85);

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Vendor Procedure SS-001, " Process Control Program for NUSPSC Radwaste solidification Systems," Revision I (8/16/85);

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Vendor Procedure SS-008, " Operating Procedure for NUSPSC Radwaste Solidification System No. 8921," Revision D (3/11/85);

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Vendor Procedure SS-010, " System Setup / Removal Procedure for NUSPSC Radwaste Solidification System No. 8921," Revision B (10/3/84);

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Vendor Procedure SS-013, " Operating Procedure for NUSPSC Radwaste Solidification System No. 8901," Revision B (5/22/85);

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Vendor Procedure SS-014, " Process Control Program for NUSPSC Radwaste Solidification Systems - Class A, Unstable Wastes,"

Revision C (5/23/85);

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Vendor Procedures SS-015, " System Setup / Removal Procedure for NUSPSC Radwaste Solidification System No. 8901," Revision A

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(2/12/85);

Vendor Procedure SS-022, " Operating Procedure for NUSPSC

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Radwaste Solidification System No. 8807," Revision A (11/16/85); and

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Verdor Procedure SS-021, " System Setup / Removal Procedure for

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NUSPSC Radwaste Solidification System No. 8807," Revision A (11/16/85).

Representatives of the site QC organization were interviewed to-determine the criteria by which successful completion of selected Inspection Hold Points was determined. The inspector noted that the site QC organization did not independently verify that the identity and activities of the various radionuclides in the shipping papers vere correct. The inspector also noted that peer review by qualified members of the Radiation Protection staff of the identities and activities of the shipped radionuclides wasn't routinely completed.

5.3 QA Surveillance Activities The site QA organization provides periodic surveillance of solid radwaste preparation, packaging and shipping activities. As noted in Detail 3.10, surveillance frequencies had been increased by the licensee. However, QA surveillance activities did not include independent verification of the identities and activities of the radionuclides as presented in the shipping. papers.

5.4 Audits The licensee's program for audits of radwaste. preparation, classification, packaging and shipping activities was reviewed.

Audit No. A60221 "Radwaste Shipment at Connecticut Yankee Power Station," (3/20 - 6/6/85) was reviewed. The audit was performed to verify the station's implementation of 10 CFR 20, 61, 71 and 49 CFR requirements. The audit was conducted by two QA auditors and a qualified technical specialist. The inspector noted that audit findings had been evaluated by licensee management (as required by 10 CFR 20.311(d)(3)).

The audit failed to note the problem with Iron-55 identification and quantification in shipping and waste manifests (See Detail 6).

.6.0 Impiementation During 1985-86, the licensee made 29 shipments of solid radwaste. Those radwaste shipments were reviewed against criteria provided in:

10 CFR 20.311, 61.55 and 61.56;

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10 CFR 71;

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49 CFR 170-189; and Station Technical Specifications and Procedures.

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The Itcansee reported that the Agreement State in which the radwaste shipments were buried had not issued any violations or warnings for the radwaste shipments received.

6.1 Vaste Generator Requirements The following waste generator requirements were reviewed and discussed with the licensee:

Waste Panifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);

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Waste Classification under 10 CFR 20.311(d)(1);

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Waste form and Characterization under 10 CFR 20.311(d)(1) and

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10 CFR 61.56; Waste shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR

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61.55; Tracking of waste shipments under 10 CFR 20.311(d), (e), (f)

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and (b); and Disposal site license conditions.

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Within the scope of this review, the following violations were noted:

10 CFR 20.311(b)' requires, in part, that the manifest

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accompanying radwaste shipments indicate as completely as practicable the radionuclide identity and quantity and the total radioactivity of the shipments.

Contrary to this requirement, the licensee failed to identify the radionuclide Iron-55 and its activity on the following radwaste shipment manifests:

Total Listed Activity Shipment No.

Descript (curies)

Date W-85-1 Dewatered resin 3.332 3/5/85 W-85-2 Dewatered filters 7,599 5/14/85 W-85-3 Cewatered filters 19.18 5/28/85 W-85-5 Compacted dry 0.747 2/20/85 activ'e waste W-85-8 Solidified ligulds 1.123 10/4/85 W-85-9 Dewatered resin 8.783 10/22/85 W-85-10 Compacted dry 0,6319 10/10/85 active waste W-85-11 Solidified liquids 0.1161 8/28/85 W-85-12 Dewatered resins 134.49 9/18/85 W-85-13 Solidified liquids 3.978 10/4/85 W-85-15 Solidified liquids 1.460 10/25/85 W-85-18 Dewatered resin 16.061 12/30/85

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Total Listed Activity Shipment No.

Descript (curies)

Date

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W-85-19 Dewatered resin.

2.192 12/20/85

.W-86-5 Solidified liquid 0.2041 2/13/86 W-86-6 Solidified liquid 5.305 2/25/86 W-86-8 Solidified liquid 1.741 3/11/86 W-86-9 Solidified liquid 2.5793 3/13/86 W-86-11 Solidified liquid 0.6091 2/10/86 The licensee's vendor analyses of various radwaste streams within the plant identified the presence of Iron-55 and provided the following scaling factors relative to cobalt-60 activity:

Waste Stream Analysed Iron-55/ Cobalt-60 ratio Reactor coolant-liquid 1.4 Resin 1.9 Filter 6.7 Dry active waste 1.5 Evaporator bottoms 1.3 The licensee determines the percent isotopic composition for the energetic gamma emitting radionuclides (e.g. cobalt-60) and a dose rate to curie conversion factor for the waste shipment container geometry based on gamma spectroscopic analysis and accepted computer programs. Calculations-of the activity of hard-to-identify radionuclides (e.g. Iron-55) are then made using the scaling factors provided in the vendor's analytical report.

For example, licensee's shipment no. W-85-12 contained 5.16%. cobalt-60 by gamma spectroscopic analysis. The scaling factor for Iron-55 in dewatered

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resins is 1.9.

The calculated total activity due to Iron-55 in the shipment would be found by multiplying the shipment's total activity by the fraction due to Cobalt-60 activity and the appropriate scaling factor, vis. (0.0516) (134.49 curies) (1.9) = 13.18 curies additional activity due to Iron-55. However, the licensee failed to list Iron-55 as a constituent'of the shipments listed above and did not conduct the calculations as shown above to determine the activity due to Iron-55 in each shipment.

The inspector calculated the estimated activity due to Iron-55 in each of shipments below:

Total Activity Percent Scaling Activity from Shipment No.

(Curies)

Cobalt-60 Factor Iron-55 (Curies)

W-85-1 3.332 71.5 1.9 4.52 W-85-2 7.599 11.0 6.7 5.60 W-85-3 19.18 13.3 6.7 17.09 W-85-5 0.747 24.1 1.5 0.27

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Total Activity. Percent Scaling Activity from Shipment No.

(Curies)

Cobalt-60 Factor Iron-55 (Curies)

l W-85-8 1.123 47.98 1.3 0.70 W-85-9 8.783 8.30 1.9 1.38 W-85-10 0.6319 28.8 1.5 0.27 W-85-11 0.1161 2.72 1.3 0'.004 W-85-12 134.49 5.16 1.9 13.18-W-85-13 3.978 57.27 1.3 2.96 W-85-15 1.460 12.03 1.3 0.22 W *5-13 16.061 0.294 1.9-0.0897 W-85-19 2.192 0.691 1.9 0.0287 W-86-5 0.2041 21.03 1.3 0.0558 W-86-6 5.305 14.26 1.3 0.983 W-86-8 1.741 23.34 1.3 0.528 W-86-9 2.5793 27.57 1.3 0.924 W-86-11 0.6091 15.17 1.3 0.120 Since Iron-55 was not identified and its activity determined for each shipment, the manifests accompanying each shipment contained

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incorrect total activities for those shipments.

Failure to identify Iron-55, determine its activity in each shipment and include the radionuclide in the total radioactivity of.the shipment constitutes an apparent violation of 10 CFR 20.311(b).

50-213/86-04-02

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10 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly described. Contrary to this requirement, the licensee certified that each of the radwaste shipments above were properly described when the identity of one of the radionuclides was missing and the activity due to that radionuclide was not identified and included in the total activity of the transported materials.

Certification that each of the waste shipments were' properly described when they were not constitutes an apparent violation of 10 CFR 20.311(c).

50-213/86-04-03 6.2 Procurement and Selection of Packaging The licensee's program for the selection of packages was reviewed against the requirements of 10 CFR 71.12, " General License: NRC Approved Package" and the Department of Transportation (00T)

requirements of.49 CFR 173, " Shippers - General Requirements for Shipments and Packaging."

The licensee's performance relative to the criteria was determined by interviews of the RMH Supervisor and members of his staff, examinations of documents, procedures and shipping records and observations during plant tours.

Within the scope of this review, no violations were note.-

6.3 Preparation of Packages for Shipment The licensee's program for preparing packages for shipment was reviewed relative to the requirements of 49 CFR Parts 172 and 173, 10 CFR 71.87 and Technical Specifications.

The. licensee's performance relative to the criteria was determined by interviews of the RMH Supervisor and members of his staff, examination of procedures,~ shipping records and other documents, and observations during plant tours of handling, storage and loading areas and licensee preparations for shipment of a cask.

Within the scope of this review, the following item was noted:

On 9/11/85, the licensee was installing a high integr'ty container (HIC) in the " Resin Pit" area and connecting lines to the container for dewatering. An Auxiliary Operator, a Radwaste Technician and a Health Physics Technician were assigned to the operation working under Radiation Work Permit No. 8502183. The

" Resin Pit" area was a high radiation area with radiation fields ranging from 100 millirem per. hour to 18,000 millirem per hour in the work area. The fitting on the HIC for the dewatering leg was a 2 inch fitting while the line used for_the dewatering contained a lh inch fitting. The Radwaste Technician was unable to make the connections for the dewatering and remained in the high radiation area attempting to connect the 2 inch fitting to the 1h inch line.

The low-range, (i.e. 0-200 millirem), dosimeter for the Radwaste Technician was noted to be "offscale".

Examination of his high range dosimeter indicated an exposure of approximately 950 millirems during the Radwaste Technician's attempts to connect the dewatering line.

The licensee's investigation and resolution of the problems encountered during the entry were reviewed. This area will be further reviewed during a subsequent inspection. 50-213/86-04-05 6.4 Delivery of Packages to Carriers The licensee's program for delivering packages to carriers was reviewed relative to criteria provided in:

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10 CFR 71.5 (a) (1) (iii), " Placarding;"

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10 CFR 71.5 (a) (1) (vi), " Shipping Manifests:d 10 CFR 71.5 (a) (1) (iv), "Public Highway - 49 CFR Part 177;"

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and licensee's Technical Specifications.and applicable procedures.

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The licensee's performance relative to the criteria was determined by review of shipping records for radwaste shipments in 1985-86, discussions with cognizant licensee personnel and ubservation of preparations for a radwaste shipment.

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Within the scope of this review, the following apparent violation was noted:

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10 CFR 71.5(a)(1)(vi) requires preparation of shipping papers in accordance with 49 CFR 172, Subpart C.

49 CFR 172.203(d)(i)

requires the name of each radionuclide in the shipment and 49 CFR 172.203(d)(iii) requires the activity of each package in the shipment be included in the shipping papers.

Contrary to the requirements, the licensee failed to include Iron-55 and the activity resulting from that radionuclide in the shipping papers associated with the radwaste shipments in Detail 6.1.

Failure to name Iron-55 and include the activity due to that radionuclide in the shipping papers associated with the radwaste shipments in Detail 6.1 constitutes an apparent violation of 10 CFR 71.5 (a) (1) (vi). 50-213/86-04-04 7.0 Exit Interview

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The inspector met with the licensee representativeshenojed,in i

Paragraph 1) at the conclusion of the inspection on Kirch 14,4986. The inspector summarized the scope of the inspection and findings asu

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described in this report.

The licensee's representative acknowledged the findings r' elated to the omission of Iron-55 in the waste manifests and shipping papers and provided the following corrective actions in response to the finding:

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Before the next radwaste shipment, the licensee will audit radwaste shipments 1984-86 to determine which shipments had incorrect' waste manifests and shipping papers due to the omisstor, of Iron-55.

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Before the next radwaste shipment, the licensee will notify the DOT and the State of South Carolina of the results of the audit.

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Before the next radwaste shipment, the licensee will revise RAP

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6.3-5 to include Iron-55 and to require an independent review of the identities and activities associated with each shipment.

The licensee will provide corrected waste manifests and shipping

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papers to the DOT and the State of South Carolina.

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The' licensee will update the Semiannual Radioactive Effluent and Waste Disposal Reports to include activities due to Iron-55.

At no time during this inspection was written material provided to the licensee by the inspector. No information exempt from disclosure under

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10 CFR 2.790 is discussed in this report.

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