ML20214K904

Further Response to NRC Re Violations Noted in Insp Repts 50-245/86-06 & 50-336/86-04 on 860324-27,per Request.Corrective Actions:Addl Training Provided to Individuals Involved in Transport of Radioactive Matl

ML20214K904
Person / Time
Site:	Millstone
Issue date:	11/19/1986
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
A05929, A5929, NUDOCS 8612020503
Download: ML20214K904 (9)

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HARTFORD CONNECTICUT 06141-0270 k L j [',[', "jZ',',"", (ict 665-5000 November 19, 1986 Docket No. 50-245 50-336 A05929 Dr. Thomas E. Murley Regional Administrator Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

References:

(1) T. E. Murley Letter to J. F. Opeka, dated July 22, 1986, Inspection Report No.

50-245/86-06, 50-336/86-06 and 50-213/86-04.

(2) J. F. Opeka Letter to T. E. Murley, dated August 21, 1986, Response to Inspection No.

50-245/86-06, 50-336/86-06 and 50-213/86-04.

Gentlemen:

Millstone Nuclear Power Station, Units 1 and 2 Update to Response to I& E Inspection No. 50-245/86-06 and 50-336/86-04 Reference (1) informed Northeast Utilities of five Invel IV violations, which were identified during inspections at the Millstone Nuclear Power Station (March 24-27, 1986). In addition to responding to the inspection report, Reference (1) directed that an update be provided every 90 days until all upgrades are completed.

Reference (2) responded to Reference (1). This report is the first 90 day update.

8612020503 861119 PDR ADOCK 05000245 I G PDR

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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 a

use, or who delivers licensed material to a carrier for'trans-port, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of DOT in 49 CPR Parts 170 through 189.

y 49 CFR 172.403(c) requires, in part, that a Radioactive Yellow-III label must be affixed to each package of radioactive i

material which 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 that a vehicle transporting packages of radioactive material must be placarded if the vehicle contains packages of licensed material that are labeled 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 from the surface of the package, and the 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 CPR 172.504(a).

This is a Severity Level IV violation. (Supplement V)

Re sponse :

Root Cause: The individual (s) responsible for the preparation of ,

shipping papers and compliance with 49 CFR regulations were not '

sufficiently trained in DOT regulations to properly label and placard this shipment.

i Corrective Steps 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 implement a continuing training program for Radwaste personnel.

The Health Physics section of the Technical Training Branch of 1 the Nuclear Training Department will complete a job analysis and procedure based task analysis in accordance with procedure NTM-1.06, " Systematic Instructional Design" for the following areas: Radwaste Handlers, Radwaste Supervision and Station l Technician (R/W), and Radwaste OA/OC by February 28, 1987.

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A set of instructional objectives resulting from this analysis effort will be produced and approved by the Training Program Control Committee for Radwaste by March 30, 1987.

A performance based continuing training program consisting of classroom and on-the-job training will be developed by July 30, 1987 and completely implemented prior to December 31, 1987.

Date When Full Compliance Will Be Achieved: The continuing training program will be established and attended by all Radwaste personnel by December 31, 1987.

90 Day Status Training program is being developed and will be implemented by December 31, 1987 as previously committed. The NUSCO Training Department will conduct a course on radioactive materials shipping for all new Radioactive Materials Department personnel as soon as practical following the hiring.

Alleged Violation:

10 CFR 50, Appendix B, Criterion II requires, in part, that the licensee shall provide for indoctrination and training of perconnel 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 Radioactive 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 ligh't of the complexity of these regulations and of the complexity of the transportation activities at Millstone Nuclear Power Station.

This is a Severity Level IV violation. (Supplement V)

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Response

Root Cause: Adequate training was not made available to individuals involved in the shipment of radioactive waste to ascure suitable proficiency was achieved and maintained as per 10 CPR 50.

Corrective Steps Taken: Millstone Station has provided additional training to individuals involved in the shipment of radioactive waste to assure suitable proficiency in the area of transportation of radioactive material. Se9 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 When Full Compliance Will Be Achieved: The continuing training program will be established and attended by all Radwaste personnel by December 31, 1987.

90 Day Status Training program is being developed and will be implemented by December 31, 1987. In the interim the Radiation Protection Supervisor - Radioactive Materials has attended Chem Nuclear's

" Workshop on Radioactive Waste Packaging, Transportation and Disposal" at Charlesten, S.C. This training was conducted on October 21 thru 23, 1986.

Alleged Violation:

10 CPR 71.12(a) permits a general license to be issued to any licensee of the Commission to transport, or to deliver to a carrier for transport, licensed material in a package for which a licensee, certificate of compliance, or other approval has been issued by the NRC.

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 compliance, or other approval of the package, and has the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging and to the actions to be taken prior to shipment.

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 documents referenced in the approval relating to the use and maintenance of this type of package.

This is a Severity Level IV violation. (Supplement V) i

Response

Root Cause: At the time of the March 5, 1986 shipment, the referenced documents were reviewed and available at Millstone Station. After the shipment was made, Chem Nuclear Systems changed the status of the cask and requested return of all company proprietary information including these documents.

Radwaste supervision was not aware of the 10 CFR 71.12 require-ments for long term retention of documents referenced in the approval of the package. At the time of the March 14, 1986 shipment, 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 shipments referenced above as required by 10 CFR 71.12. Shipment related documents and drawings required by 10 CPR 71.12 are currently being retained.

Corrective Steps To Avoid Future Violation: Radioactive shipping document and drawing retention as required by 10 CFR 71.12 will be clarified in radwaste shipping procedures.

Date When Full Compliance Will Be Achieved : Radwaste procedures will be revised to clarify document and drawing retention requirements by December 31, 1986.

90 Day Status:

Procedures are being revised and will be approved by the Site Operations Review Committee by December 31, 1986. Procedures affected include RW 6003/26003/36003 and RW 6004/26004/36004.

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, " Commitments" of the Process Control Program for 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 commencing the solidification process.

b. A general description of the solidification process including types of solidification agent, process control parameters, parameter boundary conditions, proper waste form properties, and assurance the solidification systems are operated within established process parameters.

c. A general description of sampling of at least one representative sample 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 solidify radioactive wastes for shipment to burial sites, and the vendor's procedures did not include all of the detailed information required by Item 4 of the Process Control Program in that only Item d. above was included in the procedures.

Thia is a Severity Level IV violation. (Supplement V)

Response

Root Cause: At the time of the solidification, no detailed procedures were in effect which specified the information 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 Radioactive Material Processing, Classification, Packaging, and Transportation" has been implemented which contains these process control program requirements. A new Station Administrative Control Procedure, "ACP-OA-2.01B, Quality Assurance and Quality Control in Station Radioactive Material Processing Classification, Packaging and Transportation", implements 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 comply with the process control program requirements detailed in ACP-OA-2.01B, " Quality Assurance and Quality Control in Station Radioactive Material Processing Classification, Packaging and Transportation".

Date When Full Compliance Will Be Achieved: All radioactive waste solidification procedures will be reviewed and revised as necessary to comply with ACP-0A-2.01B by December 31, 1986.

90 Day Status All Station and Vendor procedures being utilized at this time have been reviewed and revised as necessary to ensure compliance.

This action is complete.

l Alleged Violation:

10 CFR 20.311(d)(3) requires the conduct of a quality control program to assure compliance 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 Program.

Contrary to the above, on March 14, 1986, the licensee shipped 4.1 curies of radioactive material solidified in cement and packaged by a vendor to the Barnwell, S.C. burial site (Shipment No. 86-009-1), and a quality control program to assure compliance 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 Level IV violation. (Supplement V)

Response

Root 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 compliance with 10 CPR 61.56.

Corrective Steps Taken to Avoid Future Violations: Two procedures are now in effect which detail process control program requirements for compliance with 10 CPR 61.56:

NEO 6.07, " Quality Assurance and Quality Control in Station Radioactive Material Processing, Classification, Packaging and Transportation". Effective March 25, 1986.

ACP-0A-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 compliance with NEO 6.07 and ACP-0A-2.01B.

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I Date When Full Compliance Will Be Achieved: All Vendor and Station procedures involving solidification of radioactive waste will be in compliance with ACP-QA-2.01B by December 31, 1986.

90 Day Status All Station and Vendor procedures being utilized at this time have been reviewed and revised as necessary to ensure compliance.

This action is complete.

Improvements to Radioactiir Material Shipping Department In addition to the specific corrective actions taken, the following improvements have been made to the radioactive materials shipping program:

1. A re-organization of the radioactive waste group has been completed. The following new positions have been created to improve the management and preparation of radioactive materials for shipment:

Radiation Protection Sup?rvisor - Radioactive Materials Assistant Radiation Protection Supervisor - Radioactive Materials Station Technician A Radioactive Materials Handlers (7 positions)

The Radiation Protection Supervisor and Assistant Radiation Protection Supervisor positions have been filled.

Job offers are being made to the seven personnel selected as Radioactive Material Handlers. Interviews are being conducted for the Station Technician A position.

Staffing completion for the above positions is targeted for December 31, 1986.

The Radiation Protection Supervisor - Radioactive Materials will report to the Health Physics Supervisor.

2. Additional training has been provided for individuals involved in the shipment 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/QC De pa r tmen t , through the use of OA surveillance (activity observation) and inspections will monitor the processing, packaging and shipping of radioactive waste.

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At least once per month, periodic surveillance of the processing of radioactive waste including packaging and shipping will be 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 joint Corporate / Site audit program. Audits done during this period are listed below with area inspected:

NNECO OA Surveillance 073086 - Spent Resin Processing 080786 - Safety Stand for LSA Box Inspection 100186 - Procedure Compliance NUSCO OA Surveillance 092286-101086 - Radioactive Material Shipping Compliance NUSCO Radiological Assessment Branch - Health Physics Audit 082086-082186 - Radioactive Processing, Waste Classifi-cation, Area Posting, Radioactive Material Control

4. Additional programs for reducing the volume of radioactive waste are being implemented. A project assignment for improved compaction equipment has also been initiated. Super compaction equipment and/or services supplied by Scientific Ecology Group, Inc., Westinghouse and General Electric are under evaluation.

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 completed.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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'J 2 F . Opeka Senior Vice President 1

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