IR 05000382/1987006

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
Issue date:	04/14/1987
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20209F811	List: ML20209F805 ML20209F827 ML20209F854
References
50-382-87-06, 50-382-87-6, NUDOCS 8704300406
Download: ML20209F854 (7)

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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

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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

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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

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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

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

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

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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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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.