ML20127L762

From kanterella
Revision as of 19:25, 9 July 2020 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Insp Rept 50-213/85-09 on 850408-12.Violation Noted:Failure to Review & Approve Procedure 55-008 Re Radwaste Solidification Evaporator Bottoms (Tech Spec 6.8) Prior to Implementation
ML20127L762
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 06/13/1985
From: Bicehouse H, Clemons P, Myers L, Shanbaky M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127L752 List:
References
50-213-85-09, 50-213-85-9, NUDOCS 8506280122
Download: ML20127L762 (14)
v • d • e


See also: IR 05000213/1985009

Text

.- ,

,

.

U.S. NUCLEAR REGULATORY COMMISSION

.

REGION I

Report No. 50-213/85-09

Docket No. 50-213

License No. DPR-61 Priority -- Category C

Licensee: Connecticut Yankee Atomic Power Company

Hartford, Connecticut 06101

Facility Name: Haddam Neck Power Plant

Inspection At: Haddam Neck, Connecticut

Inspection Conducted: April 8-12, 1985

Inspectors: [H. bmm/Bicehouse, [d Radiatfon' Specialist _ 6//

daf.e /

9

m/ d- WS

P.~Clemons, Radiation Specialist dif e' ~ (

f  %.m /

L. Myers, Radiation Specialist

S /3

date ~ /

~

C

Approved by: 97f - Mh/

M. Shanbaky, Chief ~/

///T [$

date '

~

PWR Radiation Safety Section

Emergency Preparedness & Radiological Protection Branch

Inspection Summary: Inspection April 8-12, 1984 (Report No. 50-213/85-09)

Areas Inspected: Special, announced safety inspection by four region-based

inspectors of transportation activities, including: organization, personnel

selection, qualification and training, shipments of radioactive material,

quality assurance program, procedures, procurement and selection of packages,

and preparation of packages for shipment. This inspection involved 144

inspector hours on site by four regionally based inspectors.

Results: One violation was identified (a procedure was not followed, and

another procedure was not reviewed and approved as required, details in

Paragraph 7.1).

I

G

l

.

.

DETAILS

1.0 Personnel Contacted

1.1 Licensee Personnel

R. Graves, Station Superintendent, Connecticut Yankee

J. DeLawrence, Acting Engineering Supervisor, Connecticut Yankee

J. Beauchamp, Quality Assurance Supervisor, Connecticut Yankee

W. Nevelos, Radiation Protection Supervisor, Connecticut Yankee

R. Haight, Radioactive Materials Handling Supervisor, Connecticut Yankee

W. Heinig, Engineering Quality Assurance Specialist, Connecticut Yankee

F. Libby, Supervisor, Design and Operations Quality Assurance

M. Hornyak, Engineering Quality Assurance Specialist, NUSCo

J. Gionet, Quality Assurance Auditor, NUSCo

1.2 NRC Personnel

M. Shanbaky, Chief, PWR Radiation Safety Section

P. Swetland, Senior Resident Inspector

H. Bicehouse, Radiation Specialist

L. Myers, Radiation Specialist

Other licensee personnel were contacted and interviewed during this

inspection.

2.0 Purspose

The purpose of this special safety inspection was to review the

licensee's transportation program with respect to the following areas:

-Organization;

-Personnel selection, qualification and training;

-Shipments of radioactive material;

-Quality assurance programs;

-Procedures;

-Procurement and selection of packages;

i -Preparation of packages for shipment; and

-Delivery of packages to carriers.

3.0 Radwaste Transportation Program Organization

The inspector examined the program organization with regard to organiza-

tion structure, assignment of responsibilities and authorities, management

oversight, and inter / intra-departmental communications. The inspector's

assessment of this area was based on interviews with licensee personnel,

examination of ongoing operations, and review of procedures and applicable

l records.

!

E:

_ _ _ _ . _a-

.

.

3

3.1 Program Organizational Authorities and Responsibilitier

The organizational' structure of the Radwaste Materials Handling

(RMH) group was clearly defined. The group was made up of ten Radwaste

Materials Handling Technicians supervised by the RMH Supervisor. The

RMH Supervisor reports to the Radiation Protection Supervisor who in turn

reports to the Health Physics Supervisor. The organization charts

indicated that the RMH group had adequate supervision, and a clearly

defined reporting chain to station management.

The RMH group has the responsibilities for radioactive materials packag-

ing and transportation with the additional duties of area and respiratory

protection equipment decontamination. The RMH group authorities,

responsibilities and interfaces with other site groups were clearly

detailed in procedures ADM 11-41 Revision 7, dated March 11, 1985,

" Connecticut Yankee Administrative Control Procedure", and RAP 6.3-5,

Revision 22, dated April 8, 1985, " Radioactive Material Management."

The inspector examined the RMH group and interfacing groups staffing as it

relates to packaging and transportation of radioactive materials. The

RMH group was supported by personnel from other site groups "i.e. Opera-

tions, Chemistry and Health Physics". The RMH group staffing, training

, and qualifications (Details, Paragraph 4) were adequate to perform the

assigned radwaste handling and transportation activities.

3.2 Management Oversight

Through examination of procedures, records and interview of licensee's

personnel, the inspector determined that the WH activities were adequate-

ly supervised. During the absence of the RMH group supervisor, the

Radiation Protection Supervisor (qualified in Radioactive Waste packaging

,

and transportation), provides supervision and guidance to the RMH group.

l Transportation related documents final review and approvals are performed

l only by the RMH Supervisor, Radiation Protection Supervisor or Health

l

'

Physics Supervisor. Individuals in these positions were found to have

adequate training and experience in radioactive material packaging and

transportation (Details, Paragraph 4).

By a memorandum from the Vice President, Nuclear Operations, to distribu-

tion dated March 2, 1981, (No. 81-GN-161), a Radwaste Review Committee

(RRC) was established. The committee members were from the Connecticut

Yankee site, Millstone site and the Corporate Office.

The RRC was chartered with the responsibilities of effactively addressing

and resolving present and future radwaste problems for both Connecticut

Yankee and Millstone sites. The inspector noted that the RRC appeared to

be instrumental and effective in prescribing recommendations for radwaste

volume reduction at both sites.

.

.

4

Further examination of the RRC activities and review of the committee's

meeting minutes indicated that the committee did not meet since

May 12, 1983. The lack of committee's activity was discussed with

licensee's management. The licensee committed to reactivating this

committee. The committee will meet by the middle of May 1985 to discuss

current problems in radwaste transportation and to re-establish new goals.

3.3 Communication

The inspector examined the intra and inter groups communication as it

applies to the RMH activities. Communications within the RMH group

appeared to be adequate to relay necessary information between the group

technicians and the Supervisor. Also good communication was evident

between the RMH group and the rest of the health physics organization.

The inspector discussed with the licensee the apparent communication

problems between RMH group and other site groups. This apparent

communication problem has partially contributed to lack of QA involvement

in onsite receipt inspection of a " Category I" radwaste solidification

system and the operations of the system without QA involvement as required

by plant procedures and the QA Topical Report (Details, Paragraph 6). The

licensee stated this area will be examined.

4.0 Selection, Training and Qualification

The licensee's program for selection, training and qualification of

personnel assigned to shipping radioactive materials was reviewed against

criteria and commitments provided in the following:

Technical Specification 6.3, "Fardlity Staff Qualifications";

ANSI N18.1-1971, " Selection and Training Of Nuclear Power Plant

Personnel";

Technical Specification 6.4, " Training";

ANSI N18.1-1971, Section 5.5, " Retraining and Replacement Training";

  • IE Bulletin No. 79-19, " Packaging of Low-Level Radioactive Waste For

Transport and Burial", (August 10,1979);

Letter W. G. Counsil (Connecticut Yankee) to B. H. Grier (NRC-RI)

dated September 17, 1979;

ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program

Audit Personnel For Nuclear Power Plants"; and

I

l

__

_ _ _

.

.

5

a

10 CFR 71.105(d), " Quality Assurance Program".

The major elements of the licensee's program were reviewed including:

the basis used for the selection of personnel to be trained;

the schedules, lesson plans and performance of the training;

a

the determination of the individual's competence in the training

given; and

a

the methods used to inform personnel of changes in procedures and

requirements.

4.1 Radioactive Materials Handling Section Training

The licensee's performance in the selection, training and qualification

of personnel assigned to the Radioactive Materials Handling Section was

determined by:

  • review of the job descriptions and duties of the Radiation

Protection Supervisor (RPS), Radioactive Materials Handling

Supervisor (RMHS) and the Radioactive Waste (Radwaste) Technicians;

examination of lesson plans and training records for seven training

programs for in-house and contractor given training courses presented

since 1980;

a discussions and interviews with the RPS, RMHS and selected radwaste

technicians.

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

The licensee had implemented monthly group meetings, on-the-job training

and annual retraining programs for Radwaste Technicians. Radwaste

Technicians appeared to be thoroughly familiar with their duties and

responsibilities.

The licensee had initiated and maintained an adequate program to ensure

that Radwaste Technicians were fully informed of changes in procedures and

requirements. Guidance was provided for Radwaste Technicians serving in

supervisory positions. The licensee appeared to be implementing an

effective selection, training and qualification program for personnel

assigned to the Radioactive Materials Handling Section.

4.2 Quality Assurance Section Training

The licensee's performance in the selection, training and qualification

of personnel assigned to the Quality Assurance Section as inspectors or

monitors of radioactive materials shipments was determined by:

_ _ _

.

.

6

-.

review of job descriptions and duties for Quality Control Inspectors

and Quality Assurance Monitors;

examination of lesson plans and training records for

shipping-related training programs; and

a

discussions and interviews with the Quality Assurance Supervisor and

selected members of his staff.

Within the scope of this review, the following weakness was noted

Quality Control Inspectors did not appear to be adequately trained in

shipping and radwaste disposal requirements. Two Quality Control

Inspectors, providing inspections of radwaste shipments, were unable to

describe acceptance criteria for:

allowable radiation levels on radwaste shipments;

" free-standing" liquids in compacted, low specific activity, radwaste

shipments;

" strong-tight" containers in radwaste drum shipments; and

waste classifications under 10 CFR 61.

The training course, "QADI-5: Radwaste Shipment", was prepared and

presented by an individual with limited documented training, in NRC and

DOT requirements. The course was provided to the Quality Contrcl

Inspectors in December 1984. The instructor was a Quality Assurance

Engineer whose documented training consisted of one contractor provided

two-day seminar on radwaste. Some of his students in QADI-5 had attended

the same two-day seminar.

.

Since the site Quality Control Inspectors provide an independent review of

l the adherence to shipping and radwaste requirements, failure to adequately

train QC inspectors is considered a weakness in the licensee's program.

This item will be examined during a future inspection (85-09-01).

,

5.0 Shipments of Radioactive Material

The licensee's program for the transportation of radioactive material was

r? viewed against the criteria in 10 CFR 71.12, " General License: NRC

approved package". The licensee's performance relative to these criteria

was determined by interviewing the Radiation Protection Supervisor and the

Radioactive Materials Handling Supervisor, and by reviewing shipping

documents.

Within the scope of this review, the following was identified.

.

.

7

During the period of June-December 1984, the licensee made several radio-

active waste shipments to the burial site in Barnwell, SC. The shipments

investigated were made in NRC approved packages, and they all contained

dewatered resin.

On June 26, 1984, the licensee shipped about five Curies of radioactive

material contained in dewatered resin in package Model No. CNSI 14-170,

Certificate of Compliance (CoC) No. 9079, according to the licensee's

,

shipping documents, to Barnwell, SC.

The inspector was given a copy of CoC No. 9079, and noted that Condition

No. 5(a)(1) of CoC No. 9079 did not identify package Model No. CNSI 14-170

as an approved package. The approved packages identified in CoC No. 9079

were the NUPAC 14D-2.0, HN-100 Series 2 and HN-100 Series 2A. According

to the Radioactive Materials Handling Supervisor, the package used to make

the shipment on June 26, 1984 was marked as CNSI 14-170 and HN-100 Series

2A. Apparently the package owner (Chem-Nuclear Systems, Inc.) has not

made application to the Transportation Certification Branch of the

Division of Fuel Cycle and Material Safety to incorporate package Model

No. CNSI 14-170 into Condition No. 5(a)(1)of CoC9079.

The licensee's failure to identify package Model No. CNSI 14-170 as an

unapproved package is an indication of lack of attention to detail. The

inspector stated that it is the licensee's responsibility to assure that

all conditions of the CoC are complied with and the CoC is applicable to

the package that is used.

This item will be reviewed in a subsequent inspection (85-09-02).

During Inspection 50-213/84-11 it was determined that the licensee did not

have a quality control program to assure compliance with 10 CFR 61.55 and

10 CFR 61.56. During this current inspection it was determined that the

licensee has taken steps to establish a quality control program to assure

compliance, however, several program improvements are still needed. As

indicated in Procedure No. RAP 6.3-5, " Radioactive Material Management",

dated April 8, 1985 and Procedure No. 6.3-9, "Use of USNRC Certified

Radioactive Material Packages", there is very little involvement in either

procedure by Quality Control personnel. There are no " hold points" in

either procedure to assure quality control involvement.

On Page 27 of 65 of Procedure No. RAP 6.3-5, there are many important

,

steps to be performed that should be verified, but the only requirement

for QA is to verify the amount of water collected prior to sealing the

High Integrity Container. The lack of a significant Quality Control

,

involvement in these operations represents a weakness in the licensee's

program.

This item will be reviewed in a subsequent inspection (85-09-03)

. - - - _ _ . _- -

.

.

8

6.0 Quality Assurance QA/ Quality Control QC

A Quality Assurance program is required to be established in accordance

'

with the provisions of 10 CFR 71, Subpart H. A Commission approved QA

program which satisfies the applicable criteria of Appendix B of 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 packaging and transportation of radioactive

waste.

In addition to the general QC provisions required by 10 CFR 50, Appendix B,

specific QC requirements to assure compliance with 10 CFR 61.55 and 61.56

were mandated by 10 CFR 20.311.

The inspector examined the packaging and transportation QA/QC' activities

being implemented by the licensee's site and corporate QA organizations.

6.1 SITE QA/QC

The site QA organization was responsible for implementing all applicable

QA criteria to packaging and transportation of radwaste. The Corporate

QA organization was responsible for performing QA audits.

The site QA organization was operating in accordance with established

Administrative Control Procedures Series 1.1 and 1.2. The site QA

, organization provided QA verification of packaging compliance upon arrival

at the site. A check list with applicable items was used to verify

compliance with the packaging (i.e Casks) Certificate of Compliance

(CoC). Prior to shipment departure from the site, a QA list was used by

the site QA Technicians to check compliance with applicable requirements.

These check lists were developed to implement the requirements of Radia-

tion Protection Procedures NO. RAP 6.3-5, Revision 22, " Radioactive

Material Management", and 6.3-9 "Use of USNRC Certified Radioactive

Material Packages".

'

The inspector examined the site QA organization involvement in the receipt

of a radwaste mobile solidification system. The system was provided by

NUS and the purchase order (No. 811646) indicated that the system is a

Category I QA item. The mobile solidification system interface with plant

systems and potential for unmonitored releases from the system were

adequately reviewed by the plant Engineering Section. The inspector

examined the documentation of the Plant Design Change Request (PDER-603)

and the associated 10 CFR 50.59 and environmental evaluations. These

avaluations appeared adequate and complete.

Although adequate safety and environmental evaluations were performed by

the Engineering Section for the NUS System installation, Plant QA involve-

ment was not evident. Based on the inspector review of the QA records and

,

4

$

, _- ~ , - . _ _ . ._

-, -- --_.-_ . - . - - _ -

.

.

9

discussions with personnel, the inspector concluded that the NUS mobile

solidification system (a Category I system) was not receipt inspected and

released by the site QA organization. This was contrary to the require-

ments of QA procedures including procedures No. QA 1.2-7.1. The inspector

stated that failure to implement QA procedures was an apparent violation

of Section 6.8 of the plant Technical Specifications. (85-09-04).

The inspector examined the licensee's Quality Control (QC) program to

assure proper classification and characterization of wastes in accordance

with the requirements of 10 CFR 61.55 and 61.56. The inspector noted that

the licensee has implemented procedure No. SUR 5.6-14 " Sampling Guidelines

For 10 CFR Part 61 Compliance". The Health Physics and Chemistry Depart-

ments were responsible for implementing the procedures. Limited QC

measures were established with regard to 61.55 or 61.56 by Procedure SUR

5.6-14 or Procedure No. RAP 6.3-5. The site QA organization had a

limited involvement in assuring that dewatering operations were performed.

The site QA Technicians were to verify that a given volume of water was

removed from the package, however, no procedures monitoring was performed

by the QA organization. Also, no QA procedures for monitoring of solidi-

fication operations were available.

The inspector discussed with the licensee the QC requirements of 10 CFR

20.311. This regulation requires the licensee to conduct a quality

control program to assure compliance with 10 CFR 61.55 and 61.56. The

inspector stated that improvements in site QA/QC program, including

upgraded monitoring activities and QC program for 10 CFR 61 requirements,

will be examined during a future inspection (85-09-03).

6.2 Corporate QA

The Corporate QA organization is responsible for QA program

implementation at Haddam Neck and Millstone sites. The inspector examined

the Corporate QA program and its applicability to packaging and transpor-

tation of radioactive waste material. Corporate QA audits of this area

were being performed by Corporate QA staff. The inspector examined a

recent Corporate audit (A60425, April 1985) covering certain aspects of

Technical Specifications and Radioactive Transportation Packaging Programs

at Millstone site. Through discussions with the Corporate QA staff,

examination of QA Topical Report, review of QA procedures and QA audits,

the inspector identified the following program weaknesses:

  • Program Implementing Procedures

Although the QA Topical Report, Appendix A indicated that items and

services associated with radioactive waste packaging and transport-

ation are considered Category I QA items, the Corporate NEO and ACP

procedures did not clearly reflect the QA Topical Report require-

ments. This caused an apparent confusion as to the applicability of

10 CFR 50, Appendix B, criteria to certain packaging and transportation

.

r

-

, ,

~

.

10

activities. Also, the acceptance criteria for a given packaging or

transportation activity were not clearly defined. The licensee

stated that the QA implementing procedures will be revised to correct

these program weaknesses by August 1985.

This item will be reviewed during a subsequent inspection (85-09-05).

  • Audit Team Technical Expertise

The inspector examined the qualifications and training of the

Corporate QA Auditors. The auditors were qualified as QA Auditors

per ANSI N45.2.23, however, lack of training in the radwaste packag-

ing and transportation area was evident. The April 1985 audit was

performed by a QA Auditor without any technical expertise in radwaste

packaging and transportation. The audit team did not include staff

with technical expertise in the area of packaging and transportation.

The licensee stated that all future QA audits will be performed by a

team which includes the needed technical expertise in this area.

  • Monitoring Activities

The inspector noted that QA monitoring procydures were applied to

the radwaste transportation area in a limited scope and infrequent

fashion. The licensee stated that monitoring activities will be

performed in the future on a more frequent basis. Program impreve-

ments in this area will be examined during a future inspection

(85-09-06).

6.3 Radioactive Waste Transportation Review Group -

As a result of repeated problems in the radwaste transportation

area at the Millstone site and the subsequent Enforcement Confer-

ence held in Region I on March 25, 1985, the licensee committed to

perform a comprehensive audit in this area. To perform this

internal audit, the licensee formed the Radioactive Waste Transpor-

tation Review Group (RWTRG) and developed an action plan. The

inspector reviewed the RWTRG action plan and noted that the final

report on the status of the program was scheduled for June 1, 1985.

The inspector stated that resolution of the RWTRG findings and

concerns will be examined during a future inspection (85-09-07).

7.0 Procedures

The licensee's procedures for preparation, classification, packaging and

shipping radwastes were reviewed against criteria provided in:

Operational Phase Of Nuclear Power Plants";

.

.

.

11

(Operation)";

  • 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures And

Drawings";

  • 10 CFR 71.5, " Transportation of Licensed Materials";
  • 10 CFR 71.12, " General License: NRC Approved Packages"

, =10 CFR 20.311, " Transfer For Disposal And Manifests"; and

  • NRC/NMSS Low-Level Waste Licensing Branch, " Final Waste Classification

And Waste Form Technical Position Papers", (May 1983).

Selected procedures and radwaste shipment records were reviewed and

discussed with cognizant members of the licenseds staff. The following

procedures were reviewed for conformance to the criteria:

' Administrative Control Procedure (ACP) No. 1.2-13.5, " Entry And Exit ,

From Station Of Transporter For Nuclear By-Products (Radwaste),"

Revision 8 (1/25/85);

. * Radiation Protection Procedure (RAP) No. 6.3-5, " Radioactive Material

Management", Revision 22 (4/8/85);

  • RAP No. 6.3-9, "Use of USNRC Certified Radioactive Material Packages",

Revision 0 (4/8/85); and

  • Surveillance Procedure (SUR) No. 5.6-14, " Sampling Guidelines For 10 CFR

Part 61 Compliance", Revision 1 (3/1/85).

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

As a result of revisions to RAP No. 6.3-5 approved April 8, 1985, ACP No.

1.2-13.5 referenced inappropriate sections of RAP 6.3-5 for acceptance

criteria for shipping containers. This item is considered a weakness in

'

the control of interfaces between operating and administrative control

procedures and will be reviewed during a subsequent inspection (85-09-08).

7.1 Radwaste Preparation Procedures

The licensee's procedures for collecting, processing and preparing

i radwaste for shipment to authorized disposal sites were reviewed and

discussed with the licensee. Within the scope of this review, the

i following violation was noted:

reviewed by the Plant Operations Review Committee (PORC) and approved

by the Station Superintendent prior to implementation.

'

Contrary to these requirements, Procedure No. SS-008, " Operating

Procedure For NUSPSC Radwaste Solidification No. 8921", Revision E,

was used to solidify evaporator bottom radwaste on three occasions

and had neither been reviewed by the PORC nor approved by the Station

Superintendent prior to its implementation in those solidifications.

On October 19, 1984, the licensee shipped 2.9 Curies of evaporator

- _ _ - - .- -

m

-

.

12

bottoms solidified under Procedure No.55-008. On November 15, 1984,

a second shipment of 2.2 Curies of evaporator bottoms solidified

under the procedure was made. On March 27-28, 1985, the licensee

solidified additional evaporator bottoms under the procedure. The

procedure had not been reviewed and approved on April 12, 1985.

Failure to review and approve Procedure No.55-008 prior to its implement-

ation to solidify evaporator bottoms constitutes a violation of Technical

Specification 6.8. (85-09-04)

7.2 Waste Classification Procedures

Procedures for determining the waste classification under 10 CFR 61 and

providing a description of the radiological, physical and chemical

composition of radwaste shipments were reviewed. Within the scope of this

review, the following weaknesses were noted:

RAP No. 6.3-5 references several tables in Impe11/EAL Report

No. 02-0240-1172, "10 CFR 61 Compliance Program Northeast Utilities

Service Company Haddam Neck Plant", for determining scaling factors

used to correlate difficult-to-measure radionuclides to easier-to-

measure key gamma-emitting radionuclide concentrations in radwaste

shipments. However, those tables were not included in RAP No. 6.3-5.

The inspector noted that two copies of the Impell/EAL Report were

available, i.e. a preliminary and a final draft. Since the scaling

factors are used to determine wate classification, the scaling

factors should be controlled under plant procedures. Since neither

copy of Impell/EAL Report No. 02-0240-7771 was controlled under plant

procedures, the scaling factors used to determine waste classifica-

tion were not controlled. Failure to control the scaling factors

under plant procedures is considered a weakness (85-09-09).

  • Under RAP No. 6.3-5, dose rate to curie conversion factors were used

to determine radwaste activities for Low Specific Activity (LSA)

boxes, drums, dewatered fi1*ers and solidified wastes. Calculations

utilizing these dose rate to curie conversion factors were made for

shipments of radwastes and used to record the activities of those

shipments on shipping documents. However, records detailing the

calculations, were not available for review. Failure to maintain

records of the calculations used to determine total shipment

, activities is considered a weakness in the administrative controls

for radwaste shipments (85-09-10).

  • Under SUR No. 5.6-14, a sampling and analysis program to ensure

compliance with 10 CFR Part 61 limits was maintained. That program

monitors the Reactor Coolant System (RCS). Increased activation

product or fission product activities in the RCS noted by the

Chemistry Section are reported to Radioactive Materials Handling

Section under SUR No. 5.6-14. However, RAP No. 6.3-5 did not provide

r

.

.

~

.

13

administrative controls to evoke recharacterization of waste streams

upon significant changes in the reactor coolant activity. Failure to

provide these procedural controls constitutes a weakness in the

control of radwaste shipments (85-09-11).

8. Procurement and Selection of Packages

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 DOT requirements of 49 CFR Part 173, " Shippers-General

Requirements For Shipments and Packagings".

The licensee's performance relative to these criteria was determined by

interviewing the Radioactive Materials Handling Supervisor, and reviewing

documents.

Within the scope of this review, the following was identified.

  • As stated in Paragraph 5 of this report, the licensee used package

Model No. CNSI 14-170 to ship dewatered resin on June 26, 1984.

Administrative problems associated with the selection and procurement

of this package are discussed in Paragraph 5 of this report. In

addition, the licensee made numerous shipments of radioactive waste

to the burial site in Barnwell, SC. The shipments were made in

55 gallon drums, 4'x4'x8 metal boxes, and NRC approved packages.

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

9. Preparation of Packages for Shipment

The licensee's program for the preparation of packages for shipment was

reviewed agair st the requirements of 49 CFR Parts 172 and 173, " Shippers-

General Requirements For Shipments And Packagings", 10 CFR 71.87, " Routine

Determinations", Procedure No. RAP 6.3-5, " Radioactive Material Manage-

ment" and Procedure No. RAP 6.3-9, "Use Of USNRC Certified Radioactive

Material Packages".

The licensee's performance relative to these criteria was determined by

discussion with the Radioactive Materials Handling Supervisor, the Health

Physics Supervisor, and by reviewing appropriate documents.

Within the scope of this review, the following was identified.

  • During the period June-December 1984 the licensee made several ship-

ments of radioactive waste to the burial site in Bronwell, SC using

various NRC approved packages. The Certificates of Compliance for

these packages were reviewed by the inspector to verify licensee

compliance.

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

m

.

.

14

10.0 Delivery Of Packages To Carriers

The licensee's procedures for delivering packages to carriers were

reviewed against criteria provided in:

  • 10 CFR 71.5(a)(1)(iii), " Placarding";
  • 10 CFR 71.5(a)(1)(vi), " Shipping Manifest";
  • 10 CFR 20.311(b), " Shipping Manifest";
  • 10 CFR 20.311(c), " Certification"; and
  • 10 CFR 71.5(a)(2)(iv), "Public Highway-49 CFR Part 177".

The licensee's performance relative to these criteria was determined by

review of procedures and shipping records, discussions with cognizant

personnel and direct observation.

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

11. Exit Interview

The inspector met with the licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection. The inspector summarized the

scope of the inspection and findings. The inspector informed the plant

management that the Corporate QA program and Corporate staff involvement

in the packaging and transportation of radwaste will be examined during

an upcoming inspection at Millstone Station, inspection No. 50-245/85-11

and 50-336/85-14 during the period of April 22-26, 1985. Additional

findings related to this area will be discussed on April 26, 1985 at

Millstone Station.

At no time during this inspection was written material provided to the

licensee by the inspector. No information exempt from disclosure under

10 CFR 2.790 is discussed in this report.

Retrieved from "https://kanterella.com/w/index.php?title=ML20127L762&oldid=2900044"