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#REDIRECT [[A05929, Responds to NRC Re Violations Noted in Insp Repts 50-213/86-04,50-245/86-06 & 50-336/86-06.Corrective Actions: Addl Training Provided for Individuals Involved in Transport of Radioactive Matl & Waste]]
| number = ML20203M683
| issue date = 08/21/1986
| title = Responds to NRC 860722 Ltr Re Violations Noted in Insp Repts 50-213/86-04,50-245/86-06 & 50-336/86-06.Corrective Actions: Addl Training Provided for Individuals Involved in Transport of Radioactive Matl & Waste
| author name = Opeka J, Werner R
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = Murley T
| addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| docket = 05000000, 05000213, 05000245, 05000336
| license number =
| contact person =
| document report number = A05929, A5929, NUDOCS 8609040211
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 10
}}
 
=Text=
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e.n ewao.co        ,                                    (203) 665-5000 August 21, 1986
_Ibcket Nos. 50-213 50-245 50-336 A05929 Dr. 'Ihanas E. Murley Regional Aininistrator Region 1 U.S. Nuclear Regulatory Conmission 631 Park Avenue King of Prussia, PA 19406
 
==Reference:==
(1) T. E. Murley Intter to J. F. Opeka, dated July 22, 1986, Inspection Report No. 50-245/86-06, 50-336/86-06 and 50-213/86-04.
Centlenen:
Haddam Neck Plant Millstone Nuclear Power Station, Units 1 and 2 Response to I&E Inspection No. 50-245/86-06, 50-336/86-06 and 50-213/86-04 Pursuant to the Provisions of Section 2.201 (" Notice of Violation")
and Appendix C (Enforcanent Policy) of the NRC's Rules of Practice (10 CFR 2), this report is submitted in reply to reference (1).
Reference (1) infonned Northeast Utilities of eight Iovel IV i
violations, which were identified during inspections at the Haddam Neck Plant (March 10-14, 1986) and at the Millst.one Nuclear Power Station (March 24-27, 1986).
Millstone:
Alleged Violation:
10 CFR 71.5 requires that each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall conply with the applicable requirements of the regulations appropriate to the mode of transport of DDr in 49 CFR Parts 170 through 189.
5609040211 860821 PDR          ADOCK 05000213 G                                        PDR rc c,i
                                                                                                    \0                              -
 
49 CFR 172.403(c) requires, in part, that a Radioactive Yellow-III label must be affixed to each package of radioactive material which measures in excess of 1.0 millirem at one meter frm each point on the external surface of the package. In addition, 49 CFR 172.504 requires that a vehicle transporting packages of radioactive material must be placarded if the vehicle contains~ packages of licensed material that are labelled Radioactive Yellow-III.
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 frm the surface of the package, and the package was erroneously labelled 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).
his is a Severity Invel IV violation.      (Supplement V).
 
===Response===
Foot Cause: h e individual (s) responsible for the preparation of shipping papers and cmpliance with 49CFR regulations were not sufficiently trained in Ecr regulations to properly label and placard this shipnent.
Corrective Step Taken: Millstone Station has provided additional training to individuals involved in the transport of radioactive material. Training sessions which were held are listed on Attachment 1.
Corrective Steps to Avoid Future Violations: Millstone Station will develop and implment a continuing training program for Radwaste personnel.
      % e Health Physics section of the Technical Training Branch of the Nuclear Training Department will cmplete a job analysis and procedure based ta'sk analysis in accordance with procedure NIM-1.06, "Systenatic Instructional Design" for the following areas: Radwaste Handlers, Radwaste Supervision and Station Technician (R/W), and Radwaste OA/OC by February 28, 1987.
A set of instructional objectives resulting frm this analysis effort will be produced and approved by the Training Progran Control Ccmnittee for Radwaste by March 30, 1987.
A perfonnance based continuing training program consisting of classroom and on-the-job training will be developed by July 30, 1987 and conpletely implemented prior to December 31, 1987.
Ihte When Full Compliance Will Be Achieved: t e continuing training program will be established and attended by all Radwaste personnel by                                                ,
Ibcember 31, 1987.
 
c Alleged Violation:
10 CPR 50, Appendix B, Criterion II requires, in part, that the licensee shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
Contrary to the above, as of March 27, 1986, the Acting Radioactive Materials Handling Supervisor and the principal Radioactive Waste Materials Handler, who are involved in an activity affecting quality in the. handling of radioactive materials, were not adequately trained to assure that suitable proficiency was achieved and maintained.
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-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 cmplexity of the transportation activities at Millstone Nuclear Power Station.
This is a Severity Level IV violation.      (Supplement V)
 
===Response===
Boot Cause: Adequate training was not made available to individuals involved in the shipment of radioactive waste to assure suitable proficiency was achieved and' maintained as per 10 CFR 50.
Corrective Steps Taken: Millstone Station has provided additional training to individuals invo'lved in the shipment of radioactive waste to assure suitable proficiency in the area of transportation of.
                  ~
radioactive material. See Attachment 1.
Corrective Steps to Avoid Future Violations: Millstone Station will develop and implement a continuing training program in transportation of radioactive material to insure suitable proficiency is maintained.
Date hhen Full Cbmpliance Will Be Achieved: The continuing training program will be established and attended by all Radwaste personnel by December 31, 1987.
Alleged Violation:
10 CFR 71.12(a) permits a general license to be issued to any licensee of the Comission to transport, or to deliver to a carrrier for transport, licensed material in a package for which a license, certificate of cmplia'nce, or other approval has been issued by the NRC.
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                                    )
 
r 10 CFR 71.12(c) states that this general license applies only to a licensee who has a copy of the specific license, certificate of empliance, or other approval of the package, and has the drawirns and other doc ments referenced in the approval relating to the use and maintenance of the packaging and to the actions to be taken prior to  .
shipnent.
Contrary to the above, on March 5, 1986 and March 14, 1986, the licensee delivered licensed material to a carrier for transport to the Barnwell, S.C. burial site in a package approved by the NRC, and the licensee did not have the drawings and other doc ments referenced in the approval relating to the use and mair.tenance of this type of package.
        'Ihis is a Severity Invel IV violation.  (Supplement V)
 
===Response===
Boot Cause: At the time of the March 5, 1986 shipnent, the referenced documents were reviewed and available at Millstone Station. After the shipnent was made, Chem Nuclear Systens changed the status of the cask and requested return of all conpany proprietary information including these docments. Radwaste supervision was not aware of the 10 CFR 71.12 requirements for long term retention of doc uents referenced in the approval of the package. At the time of the March 14, 1986 shipnent, Radwaste supervision had not retained the referenced drawings for this package.
Corrective Steps Taken: Radwaste supervision obtained copies of all documents and drawings utilized in the preparation of the radioactive shipnents referenced above as required by 10 CFR 71.12. Shipnent related documents and drawings required by 10 CFR 71.12 are currently being retained.
Corrective Steps to Avoid Future Violation: Radioact.ive shipping document and drawing retention as required by 10 CFR 71.12 will be clarified in radwaste shipping procedures.
Date When Full Canpliance Will Be Achieved: Radwaste procedures will be revised to clarify docment and drawing retention requirements by December 31, 1986.
Alleged Violation:
Technical Specification 6.14, requires that the Solid Radioactive Waste Treatment System used to process wet radioactive wastes shall be operated in accordance with the Process Control Program to ensure the processed waste meets shipping and burial ground requirements. Item 4, "Ccmnitanents" of the Process Cbntrol Program Ebr the Millstone Nuclear Power Station requires that approved station or vendor procedures will include the following detailed information:
: a. A general description of laboratory mixing of a sample of the waste to arrive at process parameters prior to conrnencing the solidification process.
: b. A general description of the solidification process including      ,
types of solidification agent, process control parameters, paraneter toundary conditions, proper waste fann properties, and assurance the solidification systems are operated within established process parameters.                              -
: c. A general description of sampling of at least one representative sanple from every tenth batch to ensure solidification and action to be taken if the sample fails to verify solidification.
: d. Provisions to verify the absence of free liquid.
: e. Provisions to process containers in which free liquids are detected.
: f. Specification of the process control parameters which must be met prior to capping the container if the solidification is exothermic.
Contrary to the above, between March,1985 and March,1986, a contract vendor was used to solidfy radioactive wastes for shipnent to burial 4      sites, and the vendor's procedures did not include all of the detailed information required by Iten 4 of the Process Control Program in that only Item d. above was included in the procedures.
        'Ihis is a Severity Invel IV violation.    (Supplanent V)
Ibsponse:
Ibot Cause: At the time of.the solidification, no detailed procedures were in effect which specified the infonnation which needs to be included in Station and Vendor solidification procedures.
Corrective Steps: A corporate procedure, "NEO 6.07, Quality Assurance and Quality control in Station Padioactive Material Processing, Classification, Packaging, and Transportation" has been implemented which contains these process control program requirenents. A new Station Administrative Control Procedure, "ACP-O\-2.01B, Quality Assurance and Quality Control in Station Padioactive Material Processirn Classification, Packaging and Transportation", implenents NEO 6.07 at Millstone Station.
Corrective Steps to Avoid Future Violations: Existing Station and Vendor procedures will be reviewed and upgraded as necessary prior to use to ensure they canpiy with the process control program require-ments detailed in ACP-CA-2.01B, " Quality Assurance and Quality Control in Station Padioactive Material Processing Classification, Packaging and Transportation".
 
Date When Full Cmpliance Will Be Achieved: All radioactive waste solidification procedures will be reviewed and revised as necessary to comply with ACP-Ob2.01B by December 31, 1986.
Alleged Violation:
10 CFR 20.311(d)(3) requires the conduct of a quality control program to assure cmpliance with 10 CFR 61.56. 10 CFR 61.56 requires, in part, that waste must be structurally stable, i.e., the waste will generally maintain its physical dimensions and form under the expected disposal conditions. The licensee solidifies waste by means of its Process Control Progran.
Contrary to the above, on March 14, 1986, the licensee shipped 4.1 curies of radioactive material solidified in cenent and packaged by a vendor to the Barnwell, S.C. burial site (Shipnent No. 86-009-1), and a quality control program to assure empliance with 10 CFR 61,56 was not implemented in that the licensee did not verify that the numerous requirements specified in the Process Control Program had been satisfied to ensure that the waste was' structurally stable.
This is a Severity Imvel IV violation.                      (Supplement V)
 
===Response===
Ibot Cause: No Corporate or Station procedures were in effect at the time of solidification which addressed the process control program required by 10 CFR 61.56.
Corrective Steps Taken: A corporate policy has been implemented which details a quality control program to assure empliance with 10 CFR 61.56.
Corrective Steps Taken to Avoid R1ture Violations: TWo procedures are now in effect which detail process control program requirements for empliance with 10 CFR 61.56:
NEO 6.07, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification, Packaging and Transportation". Effective March 25, 1986.
ACP-OA-2.01B, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification, Packaging and Transportation". Effective June 24, 1986.
All vendor and Station radioactive waste solidification procedures will be reviewed and revised prior to use to ensure empliance with NEO 6.07 and ACP-OA-2.01B.
Ihte When Full Cmpliance Will Be Achieved: All Vendor and Station Procedures involving solidification of radioactive waste will be in compliance with ACP-OA-2.018 by December 31, 1986.
 
In addition to the specific corrective actions taken in response to the violations noted in this inspection, the 'following improvements have been made to the radioactive materials shipping program:
: 1.      A re-organization of the radioactive waste group has been conpleted. The following new positions have been created to improve the management and preparation of radioactive materials for shipnent:            ,
Radiation Protection Supervisor - Radioactive Ma'erials t
Assistant Radiation Protection Supervisor (Radioactive Materials)
                                                ~
Station Technician A Radioactive Materials Handlers (7 positions)
Staffing completion for the above positions is targeted for December 31, 1936.
The Radiation Protection Supervisor - Radioactive Materials will report to the Health Physics Supervisor.
: 2. Additional training has been provided for individuals involved in the shipnent of radioactive materials.        (See Attachment 1). In addition a continuing training program will be established and implemented in 1987 for individuals involved in the preparation and shipment of radioactive materials.
: 3. The site OA/0C Department, through the use of CW surveillance (activity observation) and inspections will monitor the processing, packaging and shipping of radioactive waste.                            I l
At least once per nonth, periodic surveillance of the processing                    ,
of radioactive waste including packaging and shipping will be                        I performed. The packaging and shipping aspects will also be covered via inspection and hold points in the procedures and work orders. These programs are established, working and are conducted under the ioint Corporate / Site audit program.
: 4. Additional program for reducing the volme of radioactive waste                      l are being implemented. A project assignment for improved compaction equipment has also been initiated.
A status report of upgrades and improvements in our program for preparation, packaging and shipnent of radioactive materials will be furnished to you every 90 days until the upgrades are coupleted.
  -__  _ . ~ .    -          .__  _ _          ._.  . . _ _ _ . _ . _      _ - _ _ - _ . . _ _
 
Haddan Neck:
Alleged Violation:
10 CFR 50, Appendix B, Criterion V requires, in part, that activities affecting quality shall be prescribd by procedures which include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accmplished.
Contrary t[o the above, prior to March 14, 1986, an activity affecting the quality of radioactive waste disposal, namely, verification of the identity and activity of radionuclides in radioactive waste shipnents, was performed using procedures which did not provide appropriate quantitative or qualitative acceptance criteria for verifications of the identity and activity of radionuclides in radioactive waste shipnents. Specifically, the procedures did not provide criteria for the verification of the identity and curie content of certain ne lides.
 
===Response===
Training programs were conducted for all OA/0C inspectors involved with radioactive waste materials. Also all radwaste technicians were retrained on the various aspects of their job requirements. Radwaste handling procedures were revised to incorporate " hold points".
Procedure work sheets were implemented to include all significant identified isotopes along with the criteria for verification. An independent reviewer now reviews shipping documents to ensure cmpliance with this requirement.
These actions were completed by June 13, 1986.                        <
Alleged Violation:
10 CFR 20.311(b) requires, in part, that each shipnent of radioactive waste to a licensed land disposal facility must be accmpanied by a shipping manifest which indicates as empletely as practicable the radionuclide identity and quantity and the total radioactivity of the shipnent. 10 CFR 20 311(c) requires, in part, that the manifest must include a certification by the waste generator that the transported materials are properly descrited.
Contrary to the above, between February 20, 1985 and March 13, 1986, 18 shipnents of radioactive wste, which contained several radio-nuclides including Iron-55, were sont to a burial site and were accompanied by manifests which did not identify the existence and quantity of the radionuclide Iron-56 in the shipnent. As a result, the total radioactivity stated on the manifests was in error. The nunbers of the shipments were W-85-1, W-85-2, W-85-3, W-85-5, W-85-8, W-85-9, W-85-10, W-85-11, W-85-12, W-85-13, W-85-15, W-85-18, W-85-19, W-86-5, W-86-6, W-86-8, W-86-9 and W-86-11. Further, the certifi-cations which acconpanied the manifests were also in error.
4
 
===Response===
A letter was sent to Mr. J. Still, Regulatory Affairs, Chem Nuclear Systems, Barnwell, S.C. and also to Virgil R. Autry, Director, Division of Radioactive Material Licensing and Compliance, State of South Carolina. This letter updated our shipnent activity totals for 1984, 1985 and 1986.
Procedure RAP 6.3-5 " Radioactive Material Management" has been revised ~
to require an independent reviewer to evaluate shipping documents to verify that waste shipnents are properly described.
Allhjed Violation:
10 CFR 71.5(a)(1)(vi) requires that shipping papers be prepared in accordance with 49 CFR 172, Subpart C. 49 CFR 172.203(d)(i) requires the name of each radionuclide in the shipnent and 49 CFR 172.203(d)
(iii) requires the activity of each package in the shipmnt be included in the shipping papers.
Contrary to the above, between February 20, 1985 and March 13, 1986, 18 shipments of radioactive waste which contained several radio-nuclides including Iron-55, were sent to a burial site and the shipping papers di'd not include the identity of Iron-55 in the shipnents and the activity resulting fran that radionuclide.
              . Response:
Procedure RAP 6.3-5 " Radioactive Material Management" was revised to include Iron-55 as an item of the radwaste worksheet. This will ensure the proper radionuclides will be included on the shipping
      ,      manifests and the independent review ensures that verification of shipping documants are properly described.
Very truly yours, t
NORIHEAST NUCLEAR ENERGY COMPANY CONNSCIICUT YANKEE AIUiIC POWER CCMPANY s
J.(F) Opeka        ,
Serlib. r Vice President l}
h      . hu
                      .                    By:  R. P'Werner Vice President Attachnent
 
Attachnent 1
_Radwaste Training Conducted                6
                                                                  / Attending as of 8/
Title (1)
NUS training session for Radwa t                    Dates (2)                            s e Handlers 03/31/86 - 04/01/86 Supervision, Shippers              and ve Materials nspectors OA/0C        INUS training ses (3)                                                04/02/86 - 04/04/86 NUSCo Training Department cours materials shipping        e of radioactive (4)                                                07/14/86 - 07/18/86 07/21/86 - 07/25/86 Transportation and eDisposal  Packaging,    attCNSI kbrkshop on Ra ended bySup Radioactive Materials Handling              05/28/86 - 05/30/86 i                                      ervisor 6
\
1
 
s  . .
r Attachment 1
_Radwaste Training Conducted / Attending as of 8/1/86 4                                                                  Title                                                        Dates (1) NUS training session for Radwaste Handlers                                                      03/31/86 - 04/01/86 (2) NUS training session for Radioactive Materials                                                  04/02/86 - 04/04/86 Supervision, Shippers and 0A/0C Inspectors (3) NUSCo Training Department course of radioactive 07/14/86 - 07/18/86                                                                      .
materials shipping                                                                        07/21/86 - 07/25/86 (4) CNSI hbrkshop on Radioactive Waste Packaging,                                                  05/28/86 - 05/30/86 Transportation and Disposal - attended by Radioactive Materials Handling Supervisor 1
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