IR 05000382/1987006: Difference between revisions

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{{Adams
{{Adams
| number = ML20215E282
| number = ML20209F854
| issue date = 06/15/1987
| issue date = 04/14/1987
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/87-06
| title = 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
| author name = Gagliardo J
| author name = Murray B, Nicholas J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Dewease J
| addressee name =  
| addressee affiliation = LOUISIANA POWER & LIGHT CO.
| addressee affiliation =  
| docket = 05000382
| docket = 05000382
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8706190318
| document report number = 50-382-87-06, 50-382-87-6, NUDOCS 8704300406
| title reference date = 05-28-1987
| package number = ML20209F811
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 7
}}
}}


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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
JUN 151987 In Reply Refer To:
 
Docket: 50-382/87-06 Louisiana Power & Light Company ATTN: J. G, Dewease, Senior Vice President Nuclear Operations N-80 317 Baronne Street New Orleans, Louisiana 70160 i
==REGION IV==
Gentlemen:
NRC Inspection Report: 50-382/87-06 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power and Light Company (LP&L)
Thank you for your letter of May 28, 1987, in response to our letter and Notice of Violation dated April 28, 1987. We have reviewed your reply and find !
317 Baronne Street P. O. Box 60340  -
it responsive to the concerns raised in our Notice of Violation. We will
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
review the implementation of your corrective actions during a future inspection l
  .f04FacilitiesRadiologicalProtectionSection Approved: ( f4O}lMA@n  /
to determine that full compliance has been achieved and will be maintaine
B.Murray, Chief,FacflitiesRadiological  Date Protection Section/
i 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 facilitie Results: Within the areas inspected, one violation was identified (failure to properly control, store, and protect quality assurance records, paragraph 4).


Sincerely, ORIGINAL SIGNED BY:
One unresolved item was identified (certified packaging registration, paragraph 5). .No deviations were identified.
J. P. JAUDON for J. E. Gagliardo, Chief Reactor Projects Branch cc:
Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P. O. Box B Killona, Louisiana 70066 Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P. O. Box B Killona, Louisiana 70066 Middle South Services ATTN: Mr. R. T. Lally P. O. Box 61000 New Orleans, Louisiana 70161  ,
RIV:FRPS C:FRPS C:RPSf ,R /A :R B JBNicholas/jt BMurray LAYancd J)Jaudon Ga iardo Q/Q /87 Q / /87 6/n/87
  \ L/ld/87 Q/{/87 8706190318 870615'    f i PDR G
ADOCK 05000302PDR,    /( l l
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Louisiana Power and Light Company -2-Louisiana Power & Light Company ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340 New Orleans, Louisiana 70160 Louisiana Radiation Control Program Director l
l bec to DMB (IE-06)
l l bec distrib. by RIV:
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RPB D. Weiss, RM/ALF Resident Inspector R. D. Martin, RA Section Chief (RPB/A)
0704300406 870428 PDR ADOCK 05000382
DRSP RPSB RSB MIS SYSTEM RSTS Operator RIV File Inspector Section Chief L. A. Yandell R. L. Bangart R. E. Hall Project Inspector, RPB NRR Project Inspector
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DETAILS Persons Contacted LP&L
* 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, Operation 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, 198 . 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, 198 These observations are neither violations nor unresolved items. These items were identified for licensee consideration for program improvement, but they have no specific regulatory requiremen 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 processin Low-Level Radioactive Waste Storage Facility - The licensee does not have inside weather-tight storage for the present quantity of
 
. .
,
 
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 area 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 material Defective Type B Packages - The licensee did not have a procedure to define and perform the required notifications regarding defects in Type B package Hazardous Materials Incidents - The licensee did not have a procedure to perform the required immediate notification following certain hazardous materials transportation incidents, 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 retentio . 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 ite 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
_ _ . _   .- _-
 
_
, . .
 
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
 
  , . . .
 
02.06 - Process Monitors - I


,     - . -  . . . -- _ . . . ~
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 ,
  ._._..._g,.-; . ~ - _ . - . _ .
10 CFR 61 02.01 - Management Controls 02.02 - Quality Control (QC)
7.--~._...-   ,
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
o 'e ' . , * 5
  - 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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      + P. O. BOX 60340 LO U1SI POWE A & AN LIGHTA / 317 BARONNE NEW  STPEET ORLEANS, LOU'SIANA 70160 + (504) 595 3100 NONsysM S May 28 787 W3P87-1067 A4.05 QA
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk    l .I] ~
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Washington, D.C. 20555    "( i MAY 2 919BI i
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Subject: Waterford 3 SES      . Docket No. 50-382 License No. NPF-38 NRC Inspection Report 87-06 Attached is the Louisiana Power and Light Company (LP&L) response to Violation No. 8706-01 identified in Inspection Report No. 87-0 If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-349 Very truly yours,
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    .W. Cook Nuclear Safety and Regulatory Affairs Manager KWC:PTM:ssf Attachment
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l cc: R.D. Martin, NRC Region IV
: J.A. Calvo, NRC-NRR f  J.H. Wilson, NRC-NRR NRC Resident Inspectors Office E.L. Blake W.M. Stevenson
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g g  l'AN EQUAL OPPORTUNITY EMPLOYER"
_-_______-  _ _ _


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, j 'i [ *:    Attachment to f'     ,
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W3P87-1067 Sheet 1 of 2 LP&L Response To Violation No. 8706-01 VIOLATION NO. 8706-01 Failure to Properly Store and Protect Quality Assurance Records
[ Apparent Violation
_ , Technical Spe:ificat.on 6.8.1 states, " Written' procedures shall be established, implemented, and maintained covering the activities referenced below: The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,' February 1978..."-
  '86740, Item 02.10 - Records and Reports
Specific record storage requirements are contained in the licensee's Nuclear Operations Management Manual and Nuclear Operations Procedure (N0P)-003, " Records Management System," which requires interim storage of completed records to be in. lockage, 1-hour rated, fireproof file cabinets,
^
.or access be controlled when the records are not in locked cabinet Contrary to the above, the NRC inspector determined on March 23, 1987, that the original. completed lifetime QA records generated while performing radioactive waste: shipments'for 1986.and 1987 wereistored 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 and project: files for final retentio This is a Severity Level V violatio RESPONSE (1) Reason for the Violation    .
On March 23, 1987, the NRC inspector noted that the completed original
The special scope-quality assurance requirements for Radioactive Waste Management are contained in the Louisiana Power and Light Company Nuclear Operation Management Manual (NOMM) Section VI, Chapter This management policy is implemented by Nuclear Operations Procedure (NOP)-003, " Records Management System", which identifies specific requirements for records storage and access. . The Waterford 3 Radwaste Department overlooked the storage and access requirements impostd by NOP-003 which states that "... 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". These requirements were not incorporated into the Radwaste Departmental procedure, RW-1-200,
  . lifetime QA records' generated from radioactive waste shipments made.during
  " Record Preparation, Filing and Storage".
'
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 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- Regulatory Guide 1.88, " Collection, Storage and Maintenance of Nuclear
. Power Plant Quality Assurance Records for Nuclear Power Plants" and
'
ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality-Assurance Records for Nuclear Power Plants" are included in that lis NOMM, Section VI, Chapter 5, " Radioactive Waste Management,"
<
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
"
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
_
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.


(2) Corrective Action That Has Been Taken A lockable, 1-hour rated fireproof 4 drawer file cabinet was purchased and received on 4/6/87 and completed shipping records were placed in this file cabinet on the same date.
'
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. (382/8706-01)    P Unresolved Item 86740, Item 02.05 - Procurement and Selection of Packaging J
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 an 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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Attachment to
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W3P87-1067 Sheet 2 of 2 (3) Corrective Action To Be Taken To prevent recurrence, Radwaste Departmental Procedure, RW-1-200,
.
  " Record Preparation, Filing and Storage" is being revised to reflect all requirements of record control and storage that is required by NOP-003, " Records Management System".
      ,
, . , .


(4) Date When Full Compliance Will Be Achieved Compliance with the requirements of NOP-003 were achieved on April 6, 1987. Changes to Radwaste Departmental Procedure, RW-1-200, are
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 198 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)
. expected to be complete by June 30, 198 _-
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.
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Revision as of 07:49, 5 December 2021

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


Text

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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/

i 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 facilitie 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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0704300406 870428 PDR ADOCK 05000382

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DETAILS Persons Contacted LP&L

  • 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, Operation 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, 198 . 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, 198 These observations are neither violations nor unresolved items. These items were identified for licensee consideration for program improvement, but they have no specific regulatory requiremen 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 processin Low-Level Radioactive Waste Storage Facility - The licensee does not have inside weather-tight storage for the present quantity of

. .

,

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 area 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 material Defective Type B Packages - The licensee did not have a procedure to define and perform the required notifications regarding defects in Type B package Hazardous Materials Incidents - The licensee did not have a procedure to perform the required immediate notification following certain hazardous materials transportation incidents, 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 retentio . 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 ite 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

_ _ . _ .- _-

_

, . .

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

, . . .

02.06 - Process Monitors - I

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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[ Apparent Violation

'86740, Item 02.10 - Records and Reports

^

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

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

'

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- 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 that lis 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

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

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violation of Technical Specification 6. (382/8706-01) P Unresolved Item 86740, Item 02.05 - Procurement and Selection of Packaging J

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 an 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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- -- _ -- _m - . _ ., _ . . , . , _ , , _ . . . _ . , , _ - _ _ _ . . , , _ _ _ _ _ , , , , , _ , _ _ _ . , _ _ . . _ , _

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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 198 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.