ML20127B112
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| ML20127B112 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/06/1985 |
| From: | Bicehouse H, Clemons P, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127B106 | List: |
| References | |
| 50-245-85-11, 50-336-85-14, NUDOCS 8506210358 | |
| Download: ML20127B112 (15) | |
See also: IR 05000245/1985011
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-245/85-11
Report No. 50-336/85-14
50-245
Docket No. 50-336 .
OPR-21
License No. OPR-65 Priority --
Category C
Licensee: Northeast Nuclear Energy Company
P.O. Box 270
Hartford, Connecticut 06101
Facility Name: Millstone Point Nuclear Power Station, Units I and 2
Inspection At: Waterford, Connecticut and Berlin, Connecticut
Inspection Conducted: April 15-19, 1985
Inspectors: M,YmMs [///h~
M. M. Sha'R iki,~ Chief PWR Jadiation
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Safety Section
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P. Clemons, Radiation Specialist
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Ti. Bicehouse, Rad 1#. ion Specialist
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Approved by: MY e,.gf M /
M. M. Shantaky, ChiefAWR Radiation
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Safety Section
Inspection Summary: Inspection Conducted on April 15-19, 1985 (Combined
Inspection Report Nos. 50-245/65-11: 50-336/85-14)
Areas Inspected: Special announced inspection of the licensee's
transportation program including: organization, personnel selection,
qualification and training, shipments, quality assurance / quality control,
procedures, procurement and selection of packages, preparation of packages for
shipment, and delivery of packages to carriers. The inspection involved 102
inspector-hours onsite and at the corporate offices by two regionally-based
inspectors and the Chief, PWR Radiation Safety Section.
Results: An apparent violation was noted concerning failure to follow
procedures for receipt inspections. Identified weaknesses noted in Appendix C
are discussed in this report.
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DETAILS
1.0 Persons Contacted
1.1 Northeast Nuclear Energy Company (NNECo)
*R. J. Asafaylo, Quality Services Supervisor
*G. J. Closius, Quality Assurance Supervisor
*R. J. Herbert, Station Services Superintendent
*C. Hinze, Senior Station Technician - Quality Control
*J. P. Kangley, Radiological Services Supervisor
*J. S. Kienan, Operations Supervisor - Unit 2
*J. E. Laine, Radiation Protectior Supervisor
*E. J. Mroczka, Station Superintendent
*J. M. Wood, Radioactive Materials Handling Supervisor
1.2 Northeast Utilities Service Company (NUSCO)
R. O. Bagley, Chairman, Radioactive Waste Transportation Review Group
E. Brezinski, Nuclear Fuels Branch
*J. M. Burke, Engineer - Quality Assurance
*A. J. Colello, Senior Engineer - Quality Assurance
R. A. Crandall, Supervisor - Radiological Engineering Section
*H. D. Depew, Senior Radiation Protection Technician
*J. W. Doroski, Radiological Engineer
M. Hornyak, Quality Assurance Engineering Specialist
W. R. Koste, Senior Engineer
*G. W. McElhone, Betterment / Construction Quality Assurance Supervisor
R. C. Rogers, Manager, Radiological Assessment Branch
*A. C. Saunders, Betterment /cosntruction Quality Assuraace Technician
H. W. Siegrist, Radiclogical Protection Section Supervisor
*M. Sforza, Engineer - Quality Assurance
Other individuals were also contacted during the inspection.
* denotes those individuals attending the exit interview on April 19,
1985.
2.0 Purpose
The purpose of this special safety inspection was to review the
transportation program during operation. The following areas were
reviewed:
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Organization;
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Personnel Selection, Qualification and Training;
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Shipments of Radioactive Material;
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Quality Assurance Program;
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Procedures;
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Procurement and Selection of Packages;
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Preparation of Packages for Shipment;
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Delivery of Packages to Carriers
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3.0 Radwaste Transportation Program Organization
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.The inspector examined the program organization with regard to organiza-
i tion structure, assignment of responsibilities and authorities, managegient
j oversight, and inter / intra departmental communications. The inspectors
.~ assessment of this area was based on interviews with licensee personnel, j examination of ongoing operations, and review of procedures and applicable i records. 4
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3.1 Program Organizational Authorities and Responsibilities .
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I The organizational structure of the Radwaste Material Handling (RMH) ] group was clearly defined. The group was composed of five RMH Technicians i supervised by the RMH Supervisor. The RMH Supervisor reports to the i
Radiological Services Supervisor who in turn reports to the Station -
j Services Superintendent. The licensee stated that, to improve management ,
oversight in this area, a reorganization of tra RMH group will be imple-
] mented in the near future. Under the new reorganization the RMH Super- ,
visor will report to the Health Physics Supervisor. L
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The RMH group authorities, responsibilities and interfaces with other site
j groups were clearly established by Administrative Control Procedure (ACP)
6.07 Revision 5, " Management of Radioactive Waste", Millstone Station
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Organizational Charts - January 1985, and ACP-QA-1.02 Revision 15,
- " Organization and Responsibilities". However, the RMH group interfaces
1 with Corporate staff (i.e. Radiological Assessment Branch) were not
- clearly defined. The licensee stated that improvement in this area will
- be achieved by the reactivation of the Radwaste Review Committee with
j members from the site and the Corporate staffs. l
The inspector examined the staffing of the RMH group and interfacing .
, '
groups as it related to packaging and transportation of radioactive l
materials. The RMH group was supported by personnel from other site
- groups (i.e. operations, chemistry and site QA/QC). The inspector dis-
! cussed with the licensee the RMH group staffing (i.e. five Radwaste : !
Technicians at Millstone Units 1 and 2 compared with the ten Radwaste ,
l Technicians at the Haddam Neck plant). The licensee stated that the i Radwaste Technicians at Haddam Neck have additional responsibilities for
area decontamination'and respiratory protection equipment decontamination.
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The licensee stated that it should be noted that recently increased effort
by the RMH group was needed due to additional radwaste packaging and
transportation operations (i.e. thermal shield shipments); however, the
RMH group staffing will be re-examined.
3.2 Manacement Oversight
Through examinations of procedures, records and interview of licensee's
personnel, the inspector identified the following weaknesses:
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During absence of the RMH Supervisor, a Senior Radiation Protection
Technician performs certain RMH Supervisor functions including sign-
ing of shipments for release from the site. The Senior Radiation
Protection Technician's training records indicated a lack of adequate
training to enable the individual to effectively act on behalf of the
RMH Supervisor (Details, Paragraph 4).
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By a memorandum from the Vice President, Nuclear Operations
to distribution dated March 2, 1981, (No. 81-GN-161), a Radwaste
Review Comnittee (RRC) was established. The committee members were
from the Connecticut Yankee site, Millstone site and the corporate
office.
.
The RRC was chartered with the responsibility to effectively address
and resolve 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 recommenda-
tions for radwaste volume reduction at both sites.
Further examination of the RRC activities and review of the commit-
tee'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.
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The plant procedures require the Radiological Services Supervisor to
periodically review radwaste procedures, records and logs. The
inspector noted that the Radiological Services Supervisor reviewed
certain radwaste packaging and transportation procedures. However,
other radwaste records and logs were not reviewed. The licensee
stated that the term " periodically" will be defined in the proco-
dures. Also, the new reorganization will place the RMH group under
the Health Physics Supervisor and will allow for a more timely review
of radwaste packaging and transportation procedures, records and
logs.
Licensee's actions to upgrade this area will be examined during a sub-
scquent inspection (50-245/85-11-10 and 50-336/85-14-10).
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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. Good communication was also 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. Those apparent communi-
cation problems had partially contributed to the lack of QA involvement in
onsite receipt inspection of a " Category I" radwaste solidification system i
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. personnel Selection. Qualification and Training
The licensee's program for selection, training and qualification of per-
sonnel assigned to collecting, processing, preparing, packaging and
shipping licensed materials was reviewed against criteria and commitments
provided in the following: 1
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Technical Specification 6.3, " Facility Staff Qualifications";
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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant .
Personnel";
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Te: bnical Specification 6.4, " Training";
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ANSI N18.1-1971, Section 5.5, " Retraining and Replacement Training";
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IE Bulletin No. 79-19, " Packaging of Low-Level Radioactive Waste for ;
Transport and Burial" (August 10,1979); '
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Letter W. G. Counsil (NNECo) to B. H. Grier (NRC-RI) dated September I
19, 1979- i
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10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program";
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ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program >
Audit Personnel for Nuclear Power Plants"; and
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10 CFR 71.105(d), " Quality assurance program".
The major elements of the licensee's program reviewed included:
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the basis used for the selection of personnel to be trained;
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the training schedules, lesson plans and performance of the training;
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the determination of the individual's competence in the training
given; and
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the methods used to inform personnel of changes in procedures and
requirements.
4.1 Radioactive Materials Handling Section (NNECo)
The licensee's performance in selecting, training and qualifying
personnel assigned to the Radioactive Materials Handling Section was
determined by:
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review of assigned duties for the Radioactive Materials Handling
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Supervisor (RMHS), Senior Radiation Protection Technician, Radwaste
Technicians and Health Physics Technicians assigned to the section;
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examination of lesson plans and training records for 10 training,
retraining and special-training courses provided in-house or by
contracted organizations presented since 1982;
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discussions and interviews with the RMHS and members of his staff;
and
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review of controlled routing and document acknowledgement records
for procedural training.
Within the scope of this review, the following weakness was noted:
The Senior Radiation Protection Technician assumes the duties of the RMHS
in the latter's absence. Since his assignment in 1984, the Senior Radia-
tion Protection Technician had received only limited training in packaging
and shipping requirements. The Senior Radiation Protection Technician had
received training in procedures and attended 2 days of a 5-day contrac-
tor-given training course. In contrast, records indicated that the RMHS
had attended at least 9 training, retraining and specialized training
courses in packaging and shipping requirements since 1982. Since the
Senior Radiation Protection Technician acted as the RMHS in the latter's
absence, failure to ensure that he had adequate training in packaging and
shipping requirements constituted a weakness in the licensee's training
and qualification program. At the exit interview on April 19, 1985, the
licensee's representative stated that the training of the Senior Radiation
Protection Technician would be examined and additional training provided
: as appropitate. The training of the Senior Radiation Protection Techni-
clan will be examined in a subsequent inspection (50-245/85-11-01 and
50-336/85-14-01).
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4.2 Quality Assurance / Control Section (NNECo)
The licensee's performance in selecting, training and qualifying Quality
Assurance (QA) Monitors and Quality Control (QC) Inspectors providing
overview of radioactive materials shipments was determined by:
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review of duties assigned to QA Monitors and QC Inspectors;
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examination of NUSCO Quality Assurance training program plans and
records;
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examination of training records for shipping-related training
programs for QC Inspectors; and
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discussions and interviews of the Quality Assurance Supervisor and
selected members of his staff.
Within the scope of this review, no violations deviations or weaknesses
were noted. The site Quality Assurance / Quality Control personnel appeared
to be adequately trained to perform their duties.
4.3 Quality Assurance (NUSCO)
On April 8, 1985, a corpcrate quality assurance audit of the transporta-
tion activities at the Millstone Point Nuclear Power Station was performed
by a quality assurance auditor. The training and qualification in radio-
active materials shipping for the auditor was reviewed and the following
weakness was noted:
Although qualified as an auditor under ANSI /ASME N45.2.23-1978, the
auditor had not received any training in shipping and packaging require-
ments. Failure to assign an auditor with training in shipping and
packaging requirements to audit transportation activities constitutes a
weakness in the licensee's quality assurance program.
At the exit interview on April 19, 1985, the licensee stated that
appropriate technical expertise would be included in any future audit of
transportation activities. The training of corporate QA audit team
reviewing transportation activities will be reviewed in a subsequent
inspection (50-245/85-11-02 and 50-336/85-14-02).
5. Shipments of Radioactive Material
The licensee's program for the transportation of radioactive material was
reviewed against the criteria in 10 CFR 71.12. " General License: NRC
approved package". The licensee's performance relative to these criteria
was determined by discussions with the Radioactive Materials Handling
Supervisor, and by reviewing shipping documents.
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l Within the scope of this review, the following was identified:
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The licensee has made several shipments of radioactive material during the
i period August 1984 - March 1985 to other Itcensees, and to the burial site
in Barnwell, South Carolina. The inspector examined previous shipments
that were made in NRC approved packages. The inspector's review revealed >
i a lack of attention to technical detail as indicated by the following:
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On or about October 15, 1984, the licensee made a shipment of
} radioactive waste to the burial site in Barnwell, South Carolina.
, Due to inadequate interpretation of radiation survey data taken ' ! underwater, the licensee improperly listed the container dose rate ;
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as 500 R/hr. The actual container do n rate measured by the State l q of South Carolina was 30,000 R/hr. i
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On or about July 26-27, 1984, the licensee made a shipment of radio- '
! active waste to the burial site in Barnwell, South Carolina. On 1 August 3,1984, a representative of the State of South Carolina 1 surveyed the liner containing the material, and the contact dose rate c l observed was 10,000 mr/hr. The licensee had indicated a contact dose t j rate of 150 mr/hr on the documents accompanying the shipment. S
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On or about January 7,1985 the licensee made a shipment of irradt-
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ated control rod handle assemblies to another licensee in California.
j The shipment contained 7,360 Curies of mixed fission products. 10 ,
CFR 30.41, " Transfer of byproduct material" permits licensees to
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transfer byproduct material if the licensee has determined (before '
transferring material to a specific licensee) that the recipient's
! Itcense authorizes the receipt of the type, fonn and quantity of by- !
I product material being transferred. During this inspection, the
i inspector reviewed the shipping documents for the shipment made on ! } January 7, 1985. The licensee identified the recipient's license i
permitting the receipt of 7,360 curies of mixed fission products as !
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Special Nuclear Material License No. SNM-960. This Ifeense does not ,
authorize the receipt of 7,360 Curtes of mixed fission products. !'
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Further investigation revealed that the licensee did have a copy of
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the recipient's appropriate license.
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On March 4, 1985, the licensee shipped 207 Curies of radioactive
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material contained in dewatered resin to the burial site in Barnwell, ;
i South Carolina. The shipment was made in package Model No. CNS ' j 8-120, certificate of Compliance (CoC) No. 6601. !
: , The Itcensee has developed a " Millstone Inspection Plan" to be used
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by personnel to assure compliance with the conditions of the CoC.
l The inspector determined that the "M111 stone Inspection Plan", as it j presently exists, does not address the following conditions of CoC i No. 6601: i e
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a. Prior to each shipment, a determination must be made that closure
seal replacement is current with the seal replacement schedule in
Section 8.2.4 of the application.
b. The packaging must be leak tested once every 12 months in accordance
with Section 8.1.3 of the application.
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The licensee's records for any given shipment during the period of
July 1984 - March 1985, did not " stand alone". Certain records of a
shipment were found with the Radioactive Materials Handling Super-
visor, with the QA/QC organization, in the Records Storage Area and
in the corporate office in Berlin, Connecticut. The licensee stated
that appropriate improvements to consolidate transportation records
will be made. Within the scope of this review, no violations were
identified. The maintenance of " stand alone" records will be
reviewed during a subsequent inspection. (50-245/85-11-03;
50-336/85-14-03).
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 trans-
port 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 transport packages. 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 41.56 were required by 10 CFR
20.311. Theinspectorexaminedthepackagi.19andtransportationQA/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 transportat un 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. The site QA organization provided QA
verification of packaging compliance upcn arrival at the site. A
checklist 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
checklists were developed to implement the requirements of packaging and
transportation procedures.
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The inspector examined the site QA organization involvement in the
receipt of a radwaste solidification system. The system was provided by
Pacific Nuclear Systems, Inc. and the Purchase Order (No. 811624)
indicated that the system was a Category I QA item.
The Pacific Nuclear Systems, Inc. solidification system was used at least
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three times during 1984 for the purpose of solidifying thermal shield
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chips to be disposed of at the burial site in Barnwell, South Carolina.
On, or about August 27, 1984, November 2, 1984 and December 18, 1984
three radioactive waste shipments of thermal shield chips (containing 1215
Curies, 946 Curies and 2311 Curies respectively) were processed by the
, system and sent to Barnwell, South Carolina.
Plant QA involvement in the receipt, installation, storage, and handling
of the system was not evident. Based on the inspector review of the QA
l records and discussions with personnel, the inspector concluded that the
Pacific Nuclear Systems, Inc. solidification system (a Category I system)
was not receipt inspected and released by the site QA organization. This
was contrav to the requiretrents of QA procedures including Procedure No.
ACP-QA-4.04 Revision 8. The inspector stated that failure to implement QA
procedures was in apparent violation of Section 6.8 of the plant Technical
Specifications (245/85-11-04 and 336/85-14-04).
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 had implemented Procedures No. RW6001/26001 and RW6002/26002
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for 10 CFR Part 61 Compliance. However, a comprehensive QC program was
not established to implement the regt frements of 10 CFR 20.311. The site
QA organization had a limited involvenent in assuring that the dewatering
operation was performed. The site QA Technicians were to verify that a
given volume of water was removed from the package. However, the proce-
dures failed to address QA monitoring during the dewatering process and
solidification operation.
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
licenses stated that the current QC pro 0 ram will be upgraded and QA
monitoring of transportation activities will be performed at a more
frequent basis. Upgrades to the current QC program and QA monitoring
activities will be examined during subsequent inspections (50-245/85-11
-05 and 50-336/85-14-05),
6.2 Cerporate_QA
The inspector examined the Corporate QA program and its applicability to
packaging and transportation of radioactive waste material. Corporate QA
audits of this area were being performed by the Corporate QA staff. The
inspector examined a recent Corporate Audit ( A 60425, April 1985) covering
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certain aspects of the Technical Specifications and the Radioactive Trans-
portation Packaging Program. Through discussions with the corporate QA
staff, examination of the QA Topical Report, review of QA procedures and
QA audits, the inspector identified the following weaknesses:
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Program Implementing Procedures
Although the QA Topical Report, Appendix A, indicated that items and
services associated with radioactive waste packaging and transporta-
tion 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 transporta-
tion 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 weaknesses by August 1985. These corrections will be reviewed
during a subsequent inspection (50-245/85-11-06 and 50-336/85-14-
06).
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Audit Team Technical Expertise
The inspector examined the qualifications and training of the Corpor-
ate OA Auditors. The auditors were qualified as QA Auditors per ANSI
N45.2.23. However, lack of training in the radwaste packaging 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 licensee stated that all future QA audits
will be performed by a team e tch includes the needed technical
expertise in this area. QA dadit team qualifications will be
reviewed during a subsequent inspection (50-245/85-11-07 and 50-336/-
85-14-07).
-- Monitoring Activities
The inspector noted that QA monitoring procedures were applied to
the cadwaste transportation area in a limited scope and infrequent
fashion. The last QA monitoring activity at Millstone was in 1983.
The licenseo stated that monitoring activities will be performed in
the future on a more frequent basis. QA monitoring of radwaste
transportation activities will be reviewed in a subsequent
inspection (50-245/85-11-08 and 50-336/85-14-08).
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6.3 Radioactive Waste Transpor_tation Review Group
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As a result of repeated problems in the radwaste packaging and transporta-
tion area, and the subsequent Enforcement Conference held in Region I on
March 25, 1985, the licenseo committed to perform a comprehensive audit in
this area. To perform this internal audit the licensee formed the Radio-
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active Waste Transportation 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.
7. Procedures
The licensee's procedures for the preparation, classification, packaging
and shipping of radwastes were reviewed against criteria provided in:
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Technical Specification 6.8, " Procedures";
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NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements
(Operation)";
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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures and
Drawings";
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10 CFR 71.5, " Transportation of Licensed Materials";
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10 CFR 71.12, " General License: NRC Approved Packages";
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10 CFR 20.311. " Transfer for Disposal and Manifests"; and
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NRC-NMSS Low-Level Waste Licensing Branch, " Final Waste
Classification and Waste Form Technical Position Papers" (May
1983).
Selected procedures and radwa de shipment records were reviewed and
discussed with the Radioactive Materials Handling Supervisor and members
of his staff.
7.1 Administrative Control Procedures
The following Administrative Control Procedures (ACP) were reviewed and
their implementation in selected radwaste handling and shipping
operations was examined:
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ACP-QA-4.04, " Instructions for Packaging, Shipping, Receiving,
Storage ar.d Handling", Revision 8(5/17/84);
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ACP-QA-5.01, "Non-Conforming Material and Parts", Revision 14
(2/21/85);
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ACP-QA-6.04, " Radioactive Material Shipping Requirements", Revision
15(4/18/85);
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ACP-6.07, " Management of Radioactive Waste", Revision 5 (1/3/85)
Within the scope of this review, no violations were identified.
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7.2 Radwaste Operating Procedures
The following Radioactive Waste (RW) operating procedures were reviewed
and their implementation in selected handling and shipping operations was ;
examined:
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RW 6001/26001/36001, " Waste Classification Implementation Program",
Revision 0(11/27/84);
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RW 6002/26002/36002, " Determination of the Waste Classification for
Radioactive Waste Offered for Shallow Land Burial", Revision 0
(11/27/84);
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RW 6003/26003/36003, " Radioactive Materials Shipping Compliance",
Revision 0 (1/3/85); 7
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RW 6004/26004/36004, " Shipment of Radwastes", Revision 0 (1/3/85);
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RW 6005/26005/36005, " General Radioactive Materials Shipment",
Revision 0 (1/3/85);
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RW 6006/26006/36006, " Receipt of Radioactive Material", Revision 0
(1/3/85);
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RW 6007/26007/36007, " Container Control and Accountability",
Revision 0 (1/3/85);
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RW 6008/26008/36008, " Drum Compacting Procedure", Revision 0
(1/22/85);
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RW 6009/26009/36009, "Radwaste Shipment Survey Proceduro", Revision
0(2/27/85);
-
RW 6010/26010/36010. " Loading of Chem-Nuc Shipment Cask", Revision 0
(2/27/85);
-
RW 6011/26011/36011. " Operating the Mobilo Shield Assembly (ATCOR
Cask)", Revision 0(2/27/85)
Since the RW Procedures covered operations from approximately November
1984 untti the time of this inspection, previously used procedures in the
,
Health Physics (HP) Procedure series were also reviewed as applicable to
,
various shipments.
Within the scope of this review, the following items were noted;
-
From December 1983 untti November 1984, the licensee did not have
procedures to implement wasto classification under 10 CFR 20.311/10
CFR 61.55. Each of the following procedures contained the statomont:
"Each (package typo) must be classified por 10 CFR 61.55..." but did
not provide impicmenting instructions and acceptance critoriat
_ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
-
\
.
14
.
.
*
HP 928/2928, " Shipment of Radioactive Material";
*
HP 928/2928 A-2, " Shipment of Solidified Liquid Radioactive
Waste and Spent Resin (Cask)";
* HP 928/2928 A-3, " Shipment of Radioactivity Contaminated Com-
pactible Waste"; and
* HP 928/2928 A-4, " Shipment of Radioactive Material In Drums In
Casks".
This apparent violation of 10 CFR 20.311(d)(1) was identified and
corrected by the licensee by the adoption of RW 6001/2600/36001 and
RW 6002/26002/36002 in November 1984.
-
Several procedures, (e.g. RW 6003/26003/36003, RW 6004/26004/36004,
and RW 6005/26005/36005), frequently used reference to sections of
49 CFR in lieu of step-by-step instructions and acceptance criteria.
ANSI N18.7-1976/ANS-3.2," Administrative Controls and Quality Assur-
ance for the Operational Phase of Nuclear Power Plants", Section
5.3.2(7) recommends that a procedure contain step-by-step instruc-
tions in the degree of detail necessary for performing a required
function or task. Section 5.3.2(8) recommends acceptance criteria in
procedures against which the success or failure of an activity can be
judged. Since Radwaste Technicians and others using the procedures
do not generally know the transportation requirements in 49 CFR and
have difficulty in interpreting and applying them to specific ship-
ments failure to provide step-by-step instructions and acceptance
criteria 1' the aforementioned procedures constitutes a weakness in
the administrative controls of packaging and shipping activities.
At the exit interview on April 19, 1985, the Itconsee stated that
procedures would be reviewed, revised as necessary to include
step-by-step instructions and acceptance critoria, and reviewed and
approved by August 1, 1985. Radioactive waste procedures will be
reviewed for step-by-step instructions and acceptance criteria
during a subsequent inspection (50-245/85-11-09 and 50-336/85-14-09).
7.3 Special Procedures
Shipment No. 85-004-1, (General Electric Model IF-300 cask containing
control rod blades), was reviewed to determine implementation of Special
Procedure (SP) 85-1-1, " Handling IF-300 shipping Cask," Revision 0,
2/1/85. Shipment No. 85-004-1 left the site on or about March 20, 1985
and was buried at the U.S. Ecology site in Washington on April 4, 1985.
The preparation, labeling, quality control, classification and related
supporting documentation were reviewed. The special procedure was
adequately implemented for this shipment.
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
_____
1 .
15
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.
The licensee has utilized several NRC approved packages for the shipment
of radioactive materials during the period July 1984 - March 1985.
,
Following are some examples of the packages used:
l Model No. CNS-8-120 (CoC 6601)
' Model No. CNS-14-195H (CoC 9094) !
Model No. GE-1600 (CoC 9044) l
Model No. 0H-142 (CoC 9073)
In addition, the licensee made numerous shipments of radioactive waste
using 55 gallon drums and 4'x 4'x 8' metal boxes.
Within the scope of this review, no violations were identified.
f
9. Preparation of Packages for Shipment
The licensee's program for the preparation of packages for shipment were
4
reviewed against the requirements of 49 CFR Parts 172 and 173, " Shippers
- General Requirements for Shipments and Packagings", 10 CFR 71.87,
" Routine determinations", Procedure No. RW 6004/26004/36004, " Shipment of
3
Radwastos", and Proceduro No RW 6005/26005/36005, " General Radioactive
- Materials Shipment."
,
The Itconsee's performance relat've to those critoria was determined by
j
discussiens with the Radioactive Materials Handling Supervisor, and by
reviewing appropriato documents.
" Within the scope of this review, no violations woro identified. However,
the following item was discussed with the licensoo:
L
--
The Itcenseo was not utilizing compaction for Low Specific Activity l
(LSA) boxes. Compaction was used only for LSA drum shipments. This
apparent inconsistency was discussed with the Itconsee. The Itcensee
stated that the appropriate use of compaction for volume reduction '
would be considered for LSA boxos.
l
10. Delivery of Packages _to Carrierj
The Itcenseo's proceduros for delivering packages to carriors were
reviewed against criteria provided in:
I
.
.
16
-
10 CFR 71.5(a)(1)(iii), " Placarding";
-
10 CFR 71.5(a)(1)(vi), " Shipping Papers";
-
10 CFR 20.311(b), " Shipping Manifest";
-
10 CFR 20.311(a), " 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 Itcensee's representatives (denoted in
Paragraph 1) at the conclusion of the inspection on April 19, 1985. The
inspector summarized the purpose and scope of the inspection and findings
as described in this report.
At no time during this inspection was written material provided to the
licensee by the tiispector. No information exempt from disclosure under
10 CFR 2.790 is discussed in this report.
i
e
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