IR 05000271/1985024

Insp Rept 50-271/85-24 on 850624-28.No Violation or Deviation Noted.Major Areas Inspected:Transportation Activities in Areas of Radioactive Matls Receipt & Shipping & Radwaste Disposal,Including Previously Identified Items

ML20128L080
Person / Time
Site:	Vermont Yankee
Issue date:	07/17/1985
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128L078	List: IR 05000271/1985024 ML20128L073
References
50-271-85-24, NUDOCS 8507240297
Download: ML20128L080 (8)

Text

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-24 Docket N License N DPR-28 Priority -

Category C Licensee: Vermont Yankee Nuclear Power Corporation P.O. Box 169 Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Vernon, Vermont Inspection Conducted: June 24 - 28, 1985 Inspector: .

J.*

behouse, Radiation Specialist 9lb5 ,

date Approved by: MtoCM ~7 17 $7 W~. Pasciak, Chief, date BWR Radiological Protection Section Inspection Summary: Inspection on June 24-28, 1985 (Report No.50-271/85-24)

Areas Inspected: Routine unannounced inspection of the licensee's transporta-tion activities (i.e. radioactive materials shipping / receipt and radioactive waste di 90 sal) including: previously identified items, quality assurance /qua-lity control, indoctrination and training, procedures, procurement and reuse of packagings and implementation of the progra The inspection involved 34 inspector-hours on site by a regionally-based inspecto Results: No violations or deviations were noted in the areas reviewed. The licensee was implementing a generally effective transportation program. Pro-gram improvements -in the areas of quality assurance and training were note .

8507240GP77 850719 PDR ADOCK 05000271 O PDR

,

_ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _

..: -

=

.

>

.

DETAILS 1.0 Persons Contacted t

During the course of this routine inspection, the following personnel were contacted or interviewed:

1.1 Licensee!Personr;1'

Mr. M. Fuller, Chemistry and Health Physics Assistant Mr. M. Landers,' Quality Assurance Inspector Mr. R. Lopriore, Maintenance Supervisor

• Mr. R. Morrissette, Acting Plant Health Physicist

• Mr. J. Pelletier,- Plant Manager

• Mr. E. Porter, Chemistry and Health Physics Assistant

• Mr. M. Prystupa, Acting Chemistry and Health Physics Supervisor Mr. S. Racz, Quality Assurance Engineering Assistant Mr. J. Ridley, Chemistry and Health Physics Technician Other licensee personnel were also contacted or interviewed during this inspectio .2 NRC Personnel

• Mr.' W. Raymond, Senior Resident Inspector

• Attended the exit interview on June 28, 198 . 0 Purpose The purpose of this. routine inspection was to review the licensee's trans-portation activities in the areas of radioactive materials receipt and shipping and radioactive waste (radwaste) disposal with respect to the following elements:

--

Previously Identified Items

--

Quality Assurance / Quality Control

--

Indoctrination and Training

--

Procedures

--

Procurement and Reuse of Packagings

--

Implementation

. _ _ - . _ __

_ . _ _ . _ _ _ . . _ _ . - - . __ .

"

.

.

3.0 Previoush Identified Items ,

(Closed) Violation (50-271/84-02-01) Failure to train Quality Assurance (QA) personnel in accordance with 10 CFR 71.105 (d). The actions des-cribed in the licensee's letter of September 24, 1984 were reviewe QA personnel assigned to radioactive materials shipping activities have received training in Department of Transportation (DOT) and NRC require-ments, waste burial site requirements and technical areas associated with radioactive materials shipments as described in the licensee's lette This item is close .0 Quality Assurance (QA)/ Quality Control (QC)

A Quality Assurance program is required for transport packages in accor-dance 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, Subpsrt H. The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and transportation of radioactive material 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 are required by 10 CFR 20.31 The inspector examined the packaging and transportation QA/QC activities implemented by the licensee's site and corporate QA organizations. The inspector noted that the licensee used a " peer review" forniat for QC acti-vities with surveillance and audit activities by the QA organizatio .1 Audits / Appraisals The licensee's program for audits of packaging and transportation activities (including radwasta preparation and classification) was reviewed against requirements provided in 10 CFR 50, Appendix B, Cri-terion XVIII, " Audits" and Technical Specification 6.2, " Review And Audit". The licensee's performance in this area was determined by interviews of site QA personnel and review of Audit Report Number VY-85-3B, " Radiation Protection (Health Physics) Radwaste".

Within the scope of this review, no violations were note .2 Surveillance / Inspection Activities The site QA organization provides surveillance and inspections cover-ing packaging and shipping activities. The licensee developed an in-formal surveillance directive to implement commitments in YOQAP-I-A,

"YAEC Operational Quality Assurance Manual" in response to NRC In-spection 50-271/81-08. Implementation of the directive for packaging

[

r: ,

.

and shipping activities was reviewed. Random informal surveillance of activities associated with the shipment of an irradiated control rod in the NLI-1/2 cask in October,1984, were reviewed. Surveillances of the procedural training session and loading / shipping activities were provided by e te QA personnel, i Procedure Number 0QA-X-1, " Quality Assurance Inspection", implements the licensee's QA inspections. Procedure Number 0QA-X-1 was deter-mined to be generic in nature and did not specifically reference transport packages during NRC Inspection 50-271/84-02. The licensee developed Supplement A to Procedure Number 0QA-X-1 containing a 3 part inspection checklist specifically addressing attributes to be included in transportation inspections. The inspector reviewed the checklist and discussed it with a QA representative. Appropriate acceptance criteria and regulatory limits were provided in the check-list. The inspector reviewed 5 completed checklists for radioactive materials shipments and discussed resolution of identified items on those checklist Within the scope of this review, no violations were identifie .3 Peer Review The Chemistry and Health Physics Supervisor has responsibility for receipt and shipment of radioactive material That responsibility has been delegated to a Chemistry and Health Physics Assistant re-norting through the Plant Health Physicist to the Chemistry and ealth Physics Supervisor. The Plant Health Physicist reviews radio-

tive materials shipments to assure compliance with NRC/ DOT regu-lations and plant / burial site requirements. The Chemistry and Health Physics Assistant also reviews each shipment in the same areas. This process utilizes informal checklists completed by supervisory per-sonnel to assure that each requirement is met. The inspector noted that the process was not specifically addressed in Administrative Procedure (AP) 0504, " Shipment And Receiot Of Radioactive Materials",

Revision 11, (April 5, 1985).

The insp etor reviewed the process during Radioactive Material Ship-ments Numbers 85-23 and 85-24, (i.e. shipment made during the in-spection) and determined that the process effectively inspected the shipments. However, supervisory review wasn't documented except for the signature of the Chemistry and Health Physics Assistant on the shipping form The inspector noted that the licensee had appointed a Quality Control Task Force to review all requirements related to inspections and pro-vide recommendations for improvements to the present " peer review" process for those inspection The inspector also noted that the

- .

. .

.

licensee's 0QA Audit Report, " Inspection And Test", (April 5, 1985)

had previously identified weaknesses in the independence of person-nel performing inspections, the acceptability of inspection records, and need for procedural guidance in this area.

'

The inspector discussed the formalization of the inspection process

'

for radioactive materials shipments with representatives of the Chem-istry and Health Physics Department. This area will be reviewed dur-ing subsequent inspections. 50-271/85-24-01 L4.4' Radwaste Generator QC Program Under 10 CFR 20.311 (d) (3), each licensee is required to conduct

'a quality control" program 'to assure compliance with 10 CFR 61.55 and and 61.56 requirements for waste classification and waste character-istics. The licensee's performance in this area was determined by re-view of procedures for preparing radwaste shipments, examination of records relating to shipments of dewatered resins and solidified waste liquids and discussions with the Chemistry and Health Physics Assistant and members of his staff and onsite QA representative Within the scope of this review, no violations were identifie .0 , Indoctrination And Training The general indoctrination a'nd specific training of personnel assigned to radioactive materials shipping activities were reviewed relative to cri-teria provided in 10 CFR 50, Appendix B, Criterion II, " Quality Assurance

~ Program", and commitments in the licensee's response to NRC-IE Bulletin Number 79-19, " Packaging Of Low-Level Radioactive Waste For Transport And Burial". Selected training records for, Maintenance, Chemistry 'and Health Physics and Quality Assurance personnel were reviewed and representatives from each group were interviewed regarding training for use of the NLI-1/2 and FSV-1 casks in irradiated control rod shipment Within the scope of this review, no violations or deviations were note .0 Procedares The licensee's procedures for conducting various shipping and receiving-activities were reviewed against criteria provided in 10 CFR 20.205, 10

'

CFR 71 and Technical Specification 6.5, " Plant Operating Procedures".

Procedures were reviewed to determine if instructions concerning accept-ance criteria and regulatory limits were provided for:

--

receipt of shipment containing radioactive materials; I

l

--

selection of packaging for licensee-initiated shipments;

--

preparations for shipment;

!

!

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

r'

..

• .- .

,

.

--

maintenance of packaging;

--

marking and labeling shipments and placarding vehicles;

--

monitoring shipments for radiation and contamination; and

--

providing shipments of radwaste meeting disposal site acceptance cri-teri In addition, the licensee's procedures for preparation, classi:ication, packaging and shipping radwaste were reviewed relative to criteria con-tained in:

--

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

--

NRC-NMSS Low-Level Waste Licensing Branch, " Final Waste Classfication And Waste Form Technical Position Papers", (May, 1983); and

--

Letter from R. W. Capstick, Vermont Yankee Nuclear Power Corporation to D. B. Vassalo, NRC-NRR, dated October 12, 1984 and its enclosure entitled, " Vermont Yankee Nuclear Power Corporation Process Control Program", Revision 0, (July 20, 1984).

6.1 Routine Procedures Administrative Procedure (AP) 0504, (" Shipment And Receipt Of Radio-active Materials", Revision 11, April 5, 1985) and Operating Proce-dure (0P) 2511, ("Radwaste Cask, Drum And Box Handling", Revision 11, April 5,1985) were reviewed and discussed with members of the Chem-istry and Health Physics staf Licensee Shipments Numbers 85-23 and 85-24, (made during the inspection) were reviewed for proper implemen-tation of the procedure Within the scope of this review, no violations were note .2 Special Procedures Two special procedures were developed and implemented to ship *

irradiated control rods by the licensee. Those procedures were reviewed and discussed with members of the Maintenance staff. OP 1211.01, (" Cask Loading And Handling Procedure For NLI-1/2 Cask System," Orig!nal Revision, October 18,1984) was reviewed and its implementation during Licensee Shipment Number 84-71 was examine OP 2202, (" Cask Handling Procedure For FSV-1 Cask Handling,

" Revision 1, April 5, 1985) was reviewed and discussed with members of the Maintenance, Chemistry and Health Physics and Quality Assurance staff. Implementation of OP 2202 was examined in relation to Licensee Shipment Numbers 85-16, 85-18 and 85-2 Within the scope of this review, no violations were note . _ -

,.

--

.

...

.

6.3 Radwaste Preparation /Cl'assification Procedures The licensee's procedures for collecting,' processing and preparing radwaste for shipment to authorized disposal sites were reviewed and discussed with the licensee. . 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. A.P. 0504 was reviewed for provision of specific waste disposal. site acceptance criteria, preparation of proper waste manifests under 10 CFR 20.311 and tracking of radwaste shipments until receipt by the disposal sit Within the' scope of this review, no violations were identifie .0: Procurement And Reuse Of Packages The. licensee's program for 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 Require-ments For Shipments And Packagings." Records for 14 shipments were reviewed and discussed with the licensee to determine that:

--

for shipments in packages which the licensee had registered to use, the licensee possessed copies of the specific NRC or Agreement State Certificate of Compliance, drawings, procedures and referenced documents;

---

the licensee's practices regarding use and maintenance were in accord with the applicable certificate and other documents referenced in the certificate; and

--

for NRC - certified packages, the licensee had registered with NRC-NMSS prior to the first use of the package- .

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

,

8.0 Implementation The implementation of the licensee's program for transportation of radioactive material was reviewed against criteria contained in 10 CFR 71, l

'

49 CFR 172-173 and the licensee's procedures. For radwaste shipments, criteria in 10 CFR 20.311 and 10 CFR 61.55-56 were also used in the review. Each shipment examined was reviewed to determine the adequacy of:

--

radiation and contamination measurements;

,

--

shipping paper documentation; *

L: ,

l- ~ . *

--

package marking and labeling;

-- ' . loading and stowage of~ packages;

--

vehicle placarding; and

--

notifications to state agencies for shipments of radwastes (as applicable.under 10 CFR 71.97)

.The' licensee's performance' relative to these requirements was determined by:

--

observations and measurements of 2 radwaste shipments made by the

' licensee during the inspection;

--

review of shipping records and other documents related to 5 Low Specific Activity (LSA) drum and box shipments, 4 irradiated control rod shipments and 7 Certificate of Compliance cask shipments of-dewatered resins; and

--

discussions with licensee personne Within the scope of this review, no violations were identifie .0 ' Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 28, 1985. The inspector summarized the purpose and scope of the inspection and findings as described in this' repor 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.

!'

.

, .-r - -

,-....m. . . . - ._s .__ . ,m,