IR 05000382/1988020
| ML20195D846 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/27/1988 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8811070154 | |
| Download: ML20195D846 (2) | |
Text
ss
.
.d
.
OCT 271988 In Reply Refer To:
Docket: 50-382/88-20 Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:
Thank yp[for your letter of October 10, 1988, in response to our letter dated August 24, 1988 (Unresolved Item 382/8820-02), and telephone request of September 9,1988, for detailed information on your actions to resolve several State of Nevada identified violations of the U.S. Department of Transportation (00T) regulations involving radioactive waste shipments from your facility.
These violations involved several of your radioactive waste shipments to the Beatty, Nevada burial site during the period of May 31, 1988, through June 6, 1988. Your corrective actions appear to be sufficient to prevent future recurrence of the violations. We find your response fully responsive to our request and we have no further questions at this time. We will examine implementation of your corrective actions to these 00T violations during a future inspection. We will also determine at that time whether further enforcement action is warranted.
Sincerely
.
Original Signed By, L J. Callan L. J. Callan, Director i Division of Reactor Projects cc:
Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P.O. Box B K111ona, Louisiana 70066 Louisiana Power & Light L.epany ATIN: N. S. Carns, Plant Manager P.O. Box D Killona, Louisiana 70066 Middle South Services ATTN: Mr. R. T. Lally P.O. Box 61000 New Orleans, Louisiana 7 161 RIV:FRPMPB C:FRPS:R C:RpBk SA 0:0 DCh eW RBaerj/88 BMurray Chamberlain Callag
@ /88 l0 /p $ /88 je/t,/88 [0/ /88 t
f 8811070154 881027 ,
DR ADOCK0500g8g
. - -
>t .,f 4 Lout siana Power & Light Company -2-Louisiana Power & Light Company ATTN: R. F. Burski, Acting Manager Nuclear Safety and Regulatory Affairs 317 Baronne Street P.O. Box 60340 New Orleans, Louisiana 70160 Louis',ana Radiation Control Program Director bec to DMB (IE06)
bec distrib. by RIV:
RRI k. D. Martin, RA Section Chief (DRP/A) DRP RPB-DRSS MIS System Project Engineer, DRP/A RSTS Operator RIV File D. Wigginton, NRR Project Manager DRS Lisa Shea, RM/ALF Inspector B. Murray R. Baer J
3 g 5 ;; W. t b 'J. ' ,. . . T
.
.- -
0 ,
,
,
@' M e L s a. O 80x 60340 LO UISI AN A / 3irNEW P O W E A & t. I G H T eAneNNe STaseT-OnLEANS. LOUISI AN A 70160 * (504) 595-3100 Y
N N S sIET*
October 10, 1988 W3P88-1919 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 SUBJECT: Waterford Steam Electric Station - Unit Number 3 Docket Number 50-382 NRC Inspection Report 88-20 Gentlemen:
The subject Inspection Report identified unresolved item 8820-02 regarding transportation-related violations issued by the State of Nevada against low level radioactive waste shipments from Waterford 3 to the Beatty, Nevada disposal site. Messrs. D. Chaney and R. Baer, NRC Region IV, requested a letter summarizing the status of these violations durfrg a conference call on September 9, 1988. This letter responds to their Yaquest.
Low level radioactive waste shipment numbers 88-1008 and 88-1009 arrived at the disposal site o May 31, 1988 and June 3, 1988, respectively; 88-1010 and 88-1011 both arrived on June 6, 1988. These shipments all arrived within a one week period and are the shipments for which violations were issued. The violations can be summarized as follows:
1. Manifests accompanying shipment numbers 88-1008, 1009, and 1011 each had an illegible copy attached; 2. One of the placards on the front of the vehicle transporting shipment number 88-1008 was improperly displayed; and 3. Shipment number 88-1010 appeared to have shifted slightly during transport and a small hole was found on the front of one of the packages in the shipment.
Another violation had been issued against shipment number 88-1010, citing discrepancies between package dose rates indicated on the manifest and those measured at the disposal site. This violation was rescinded, however, after Louisiana Power & Light Company (LP&L) contacted the disposal site Radiation Safety Officer and demonstrated that the violation could not have been issued against LP&L's shipment.
- 7
"AN EQUAL OPPORTUNITY EMPLOYER"
$ ;al M C
'
J Q' r s - n a
.o u a m w ew +~
i u_.
p.//.r
-.
_._____,_________-_-__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ _
s,
.
b
.
,
Page 2 V3P88-1919
- October 10, 1988 ,
LP&L instituted corrective actions, including procedural revisions and j review of the violattens, regulatory requirements and procedural revisions t
with personnel involved with radioactive waste shipeer.ts in response to these violations. These actions were detailed in letters to the State of Nevada dated July 5, 1988, July 25, 1988, and August 4, 1988. The State of Nevada acknowledged LP&L's corrective actions in letters dated July 12, !
1988, August 1, 1988, and August 12, 1988; and provided clarification that l a LP&L could resume shipments to Beatty in a letter dated September 19, 1988. '
LP&L feels that it has appropriately addressed these violations, and based on correspondence from the State of Nevada, considers these violations closed.
Messrs. Chaney and Baer indicated during the aforementioned conference call that unresolved item 8820-02 could be closed based on documentation of resolution by the State of Nevada. Copies of all correspoadence referenced j in this letter, plus the letter rescinding the dose rate violation, and the !
,
letters citing the violations are attached for your review. These i i
attachments comprise a complete package of all correspondence related to ,
the violations and document the fact that this issue has been resolved with l the State of Nevada, pending inspections of future shipments to Beatty to !
verify that the corrective actions have been effective. LP&L therefore j
,
requests that unresolved item 8820-02 be closed. l l
4 Specifies of the violations and corrective actions have not been reiterated !
!' in this letter as the information is fairly detailed and clearly presented !
in the attached correspondence. Should you wish to discuss this matter i further or require additional information, please contact Chadi D. Croome "
i at (504) 595-2846, i
] Yo rs very truly,
! -
g
,
i R. Burski j
- M ager !
Nuclear Safety & Regulatory Affairs RFBtCDGtssf -
Attachments cet E.L. Blake, W.H. Stevenson, J.A. Calvo D.L. Wigginton, 4.D. Martin. i NRC Resident Inspector's Office (W3)
- i i O
List of At tached correspondence O
State of Nevada to LP5L - 8 letters dated:
June 7, 1988 June 30, 1988 (3 letters)
July 12, 1988 August 1, 1988 August 12, 1988 September 19, 1988 LP6L to State of Nevada - 3 letters dated:
July 5, 1988 July 25, 1988 August 4, 1988
- , \ fy. M-Z~~ " '
- '
, c.tcHaRo H smu% STATE OF NE\ ADA L 4wNt %[ P W 4f H[h
- G+.erae< u . . . u . .. . ..
JEZY GRitPENTROG JOgtPH Q J AR% I% 4D D=*<ie' g. ,
n, .i, = o,s .< ,.
'
,. ; . .
DEPARTMENT OF HUMAN RESOURCES HE ALTH Dl%3510N m.o.l. sic.i Hestih 5.cii.n 505 East King Street. Room 203 Carson City. Nevada 89710 (702) 885 5394 June 7, 1988 Louisiana Power and Light Company 317 Baronne Street New Orleans, LA 70160 Ce.ir Mr. Cain:
.
This letter is in reference to Louisiana Power and Light Company LLW shipment no. 88-1008 which arrived at the Beatty, NV disposal site on May 31, 1988 under Nevada Site User Permit No. Q446.
Inspection findings revealed the follcwing violations:
1. 001-Q446-4-1 U.S. Department of Transportation regulation 49 CFR 172.516(c)(4) requires each placard to be located away f rom any marking, such as advertising, that could substantially reduce its effectiveness, and in any case, at least 3 inches (76.0 mm.) away from such markings.
Contrary to this requirement, the placard located on the front of the transport vehicle was located within three (3) inches of a license plate holder which was displaying four license plates.
The top of the placard was also wrapped over the top of the vehicle bumper which should be prevented on future shipments.
The entire placard must remain completely visible.
2. 001-Q446-4-2 49. CFR 172.201(a)(2) states that the required shipping description on a shipping paper and all copies thereof use for transportation purposes, must be legible and printed (manually or mechanically ) in English.
M ! 41988
_
. . -- .-
A
.. *T
,. .
Contrary to tnis requirement, the carrier copy of the shicp;ng manifest furnished with the shipment had several portions which
'
were not clearly legible. The violation appears to be a result of an improper printer font or inadequate pressure on the printer.
You are required to advise this office in writing within 20 days of your receipt of this letter to indicate the actions that will be taxen to correct these violations, when the corrective actions will be implemented and the methods that will be taken to prevent recurrence of the violations.
Sincerely, ( 'l k,M g0n Stanihy) R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services Enclosure 11wsiplevioltr ,
,
cc: Bill Spell, State of Louisiana virgil Autry, State of South Carolina .
'
Earl Ingersoll, State of Washington Jr,4. / r' :- ~
Jack Hornor, Region V, NRC Bert Gray, Nevada Health Division
.
- . _ . - -- . - _ _ - _ . - _- __
. . . i :
.
.
,
'
,
[
l
.
,
i -
e.A . . ~.;; --
.
'
a :n ,.,
~
~
l
,
s RADl040TlVE ,.P
. '
!
m *#
, . :., ,1
.g . Y$ l'f',
,
,amar.im < '
% 1 *%:.'*}
.
.
,u
-
.
- J .'.' ppg.').
( i t
'
l ----u..._. _
.
l _
C941.7,
. ..
l
,
~~
C 05-3T'88 [
l LOUSIANA Pok'ER & LIGEI l I
,
k IMPROPERLY DISPLAYED PIACARD
-- --
_____m,,
i
l
!
i
,
f i
l
'
ja
~
,.:,g a s e e al(Hopt) H 873 4% STATE OF NE\ AD A Lautut a w it r e -
,
, Gds trade 4J e a seen ,e JERTM G21(Pt%f;OG JO%EPH Q J42t h wJ o.m s e, ,4 H, .o a o. .. ,.
3 ,,
.
DEPARTMENT OF HUMAN RESOURCES HE ALTH D1%I510%
Radeelegnal Health lettien 505 East King Street. Room 203 Carson City. Nesada 89710 (702) 885 5394 June 30, 1988 i
J. Louisiana Pcwer and Light Company 317 Baronne Street New Orleans, LA '70160 RE: 003-Q446-2-1 003-Q446-3-1 003-Q446-3-2 -
,
Dear Mr. Cain:
This letter is in reference to the Louisiana Power and Light company LLW shipment number 88-1010 which arrived at the Beatty site on June 6, 1988. The shipment was made under Nevada Site User Permit No. Q446 issued to Louisiana Power and Light Company, Waterford 3 SES.
Inspection findings revealed the following violations:
1. 003-Q446-2-1 U.S. Department of Transportation regulation 49 CFR 173.425(b)(1) requires materials to be packaged in strong, tight packages so that there will be no leakage or radioactive material under conditions normally incident to transportation.
Contrary to this requirement, package number 88-0111 was found to have a hole in the front of the package. The hole was approximately 1/4 inch in diameter and was located 20 inches from the left side and 20 inches from the bottom of the package. No loss of container contents was found as a result of the hole in the package. l 2. 003-Q446-3-1 JUL g 198?
L
_ . _ -
--____ ___ ._. _ _ _____
.. .,
,. .
49 CTR 173.415(b)(6) requires the shipment t0 he braced s as ::
prevent shi: ting of lading under conditions ncrmally inciden: ::
-
transportation.
49 CFR 173.448(a) requires each shipment of radioactive material to to secured in order to prevent shifting during normal transpcrtation conditions.
Contrary to tnese requirements, tne containers were found to have shifted to tne front of the trailer as a result of the woeden wedges ceing released from between the containers curing transit.
The release of the wedges created approximately 6 inches of space between the rear floor bracing materials and the rear packages.
3. 003-Q446-3-2 Nevada Administrative code 459.823(2) requires the manifest te
>
contain a statement which is as complete as is practicable and includes a physical description of the waste, its volume, the identity and quantity of radionuclides, the total radioactivity and the principal enemical form.
Contrary to this requirement, three packages were found to . .
have external radiation levels significantly different than the
- radiation levels indicated on the shipping manifest. The three
! packages, the indicated levels and measured radiation levels are as follows:
package No. Indicated rad. level Measured rad, level 0111 800.0 mR/hr 550.0 mR/hr I
'
'
0049 60.0 mR/hr 100.0 mR/hr i 0047 80.0 mR/hr 110.0 mR/hr f
Mr. Larry Simon from your company was present during confirmation of the findings above. ;
You are required to advise this office in writing within >
20 days of your receipt of this letter of the actions that will be taken to correct the violations, when the corrective actions will be implemented and the methods that will be used to prevent recurrence of the violations.
Upon receipt of the correctiva actions, we will review the response and advise you concerning resuming shipments to the
.
Beatty site.
i
!
- . - _ - . _ - - - - - - - _ . - - - . _ _ - .
_ _ _ _ _
~. , .,
- , , .
If you have any questions, please feel free to contact me.
.,.
Sincerely, h
Stanigly R. Marshall. Supervisor
~
Radiological Health Section Bureau of Regulatory Health Services lw2\lplcitr cc: Bert Gray, Nevada Health Division Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Jack Horner, Region V, NRC Bill Spell, State of Louisiana Novelle Tucker, U.S. DOT
.
1 i
!,
,_-. _. ,__ - , _ _ _ _ . .
, ,
p e it ; i. e. < w
- ' RICHnRO H 87.Y 4 % STATE OF NE% AD4 L4watsct P w n! Hits
,
, . ce.or w 4 a . . . . w . ..
JERRY ORitPt%f2OG JOSEPH Q J4Rtl% MD c.reereo ,
Hees orro<,,
I
.
DEPARTMENT OF HUMAN RESOURCES HE Alf H DIVISION Radlelegkal Health Se<tten 505 Esot King Street, Room 203 Carson City, Nevada 89710 (702) 885 5394 June 30, 1988 J. Louisiana Power and Light Company 317 Baronne Street New Orleans, LA 70160 RE: 002-0446-4-2 .
-
Dear Mr. Caint This letter is in reference to the Louisiana Power and Light Company LLW shipment number 88-1009 which arrived at the Beatty site on June 3, 1988. The shipment had been made under Nevada Site User Permit No. Q446 issued to Louisiana Power and Light Company, Waterford 3 SES.
Inspection findings revealed the following violation:
1. 002-0446-4-2 U.S. Department of Transportation regulation 49 CFR 172.201(a)(2) requires the shipping description on a shipping paper and all copies thereof used for transportation purposes, to be legible and printed (nanually or mechanically) in English.
Cont rary to this requirement, the carrier copy of the shipping man;fest f hed with the Louisiana Power and Light Company shipment n 88-1009 was not legible. This appears to have been caused the printing style of the manifest printer.
You are required to advise this office within 20 days of your receipt of this letter of the actions that will be taken to correct the violation, when the corrective actions will be implemented and the methods to prevent recurrence of the violation.
,
JUL 619Q
. _ _ _ _ _
o. ..
, .
,
If you have any questions, please feel free to contact me.
-
Sincerely, Sta Wey R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services lw2\lplevioltr cc: Bert Gray, Nevada Health Division Jack Hornor, Region V, NRC Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington Bill spell, State of Louisiana Novelle, Tucker, U.S. DOT
.
e
.
l..
,
/4 t e.- +..t c < --
.
'
' c:. ,a n.
,
4*-..w....
JERRY GRitPt%TIOG JOttPH Q 8 4;;\ l% 40 p.,...
,
u,.o a o.. .. .,
.
DEPARTMENT OF HUMAN RESOURCES HEALTH 04%I510N Roseleg6 sal Health Section 505 East King Street. Room 203 Carson City, Nevada 89710 (702) 885 5394 June 30, 1988 J. M. Cain Louisiana Power and Light Compaty 317 Baronne Street New Orleans, LA ,70160 '
RE: 004-Q446-4-3
Dear Mr. Cain:
i
,
This letter is in reference to the Louisiana Power and Light company LLW shipment number 88-1011 which arrive at the Beatty site on June 6, 1988. The shipment had been made under Nevada Site User Permit No. Q446 issued to Louisiana Power and Light :
Company, Waterford 3 SES. !
Inspection findings revealed the following violation: (
1. U.S. Department of Transportation regulation 49 CFR 172.201(a)(2) requires the shipping description on a shipping paper and all copies thereof used for transportation purposes, to be legible and printed (manually or mechanically) in English.
Contrary to this :;equirement , the carrier copy of the manifest could not be read. This appears to have been caused by the printing style of the manifest printer, you are required to advise this office within 20 days of your i receipt of this letter of the actions that will be taken to ,
correct the violation, when the corrective actions will be implemented and the methods to prevent recurrence of the violation.
>in erely, i
' L. _ _
'
a y R. Marshall, Supervisor Radiological Health Section Bureau of Regulatory Health Services JUL 6 1988
..
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
.o . ,
. .
.,
lw2\1picio21tr !
^
cc: Bart Gray, Nevada Health Division ,
Jack Hornor, Region V. NRC Virgil Autry, State of South Carolina Earl Ingersoll, State of Washington l
Bill Spell, State of Louisiana '
Novelle Tucker, U.S. DOT f
,
!
.
e e
)
,
D e
w
_. _ _ _ _ - - - _ _ _ _ _ _ _ _ _ .
<=,.s -: a i
,m, ...q.,
,
s... ,
- [tCm bilit %f ROG ,m t. .s, F w g u,. 2 o..,,..,
.,.,,- . , , . . . . . .
.
DEPARTMENT OF HUMAN RESOURCES HE4LTH Dl%IblO% i n,ai.i. ...i H..iin se.....
SC Ea .: King Street. Room 203 arson City. Nnada 89710 1702) 885 5394 July 12, 1988 ;
>
R. F. Burski, Manager Nuclear Safety and Regulatory Affairs Louisiana Power and Light C mpany ,
P.O. Box 60340 Mall Unit N-17 New Orleans, LA '70160 ,
,
Cear Mr. Burski:
Your letter dated July 5, 1988 is acknowledged. The letter describes the actions that have been taken to correct the violations documented during our recent inspection of Louisiana
. Power and Lignt Ccmpany LLW shipment number 88-1008.
The corrective actions will be reviewed during future inspections. ;
You are requested to respond to the violation letters concerning shipment numbers 88-1009, 88-1010 and 88-1011 prior to resuming shipments to the Beatty site.
If you have any questions, please feel free to contact this office.
!
' h at ely,
'
r%
'3 t d y R. Marshall, Supervisor '
Racio 1gical Health Section Bureau of megulatory Lalth Services cc: Bert Gray, Nevada Health Division Bill Spell, state of Louisiana l Virgil Autry, State of South Carolina t Earl Ingersoll, State of Washington Jack Hornor, Region V, NRC Novelle Tucker, U.S. Dept. of Transportation
!
W orJ 14 3 . ;J ..! : '
aI w.; - .f4 -- -
3aysw 5 TATE or NEVtDt. d LAe s.t,i.cr.
. , . . .P. .anatHall
.
AICHA.R)
. . . . . .H
.
40$tPM Q JAR \ll. M f,.
Jimmy GaltPEMISOC Meer eb Cl;tse.
On.e n e. l I
DEPARTMENT OF HUMAN RESOURCES HLALfH O(VilWM Red 8. lee $aal Meettt lectlen 505 East Klag Street. Roofa 203 .
Careen City. Nevede s9710 August 1, 1998 0o2) ses.5394 R. F. Burski, Manager Nuclear Safety and Regulatory Affairs Louisiana Power & Light 317 Baronne Street New Crleans, LA 70160 RE: 002-0446'-4-2 004-Q446-4-3
Dear Mr. Burski:
Your letter dated July 25, 1988 is acknowledged. The letter describes the actions that have been or will be taken to correct the violations documented during recent inspections of LLW shipments from Louisiant Power & Light.
The corrective actions will be reviewed during future inspections to deternine their effectiveness. We are still awaiting a response to our letter dated June 30, 1988 concerning your LLW shipment number 88-1010.
Upon' receipt of the response, we will consider reinstatement of permission to ship to the Beatty site.
If you have any questions, please feel free to contact me.
incerely, h
- a y R. Marshall, Supervisor Radiological Health Section Bureau cf Regulatory Health Services lw2\lpl81txt cct Bert Gray, Nevada Health Division .
Jack Hornor, Region V. NRC '
Virgil Autry, state of South Carolina Earl Ingersoll, state of Washington Bill Spell, State of Louisiana Novella Tucker, U.S. Dept. of Transportation
..
SEP 15 '88 14: 16 PAGE.002
_ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _
. * AICnteo H smag STATE OF st%ADA t .4 mi v .. , . . . . , ,
. . Geof*S4+ 46 =. evens e JtRTy GCit PENTOOG '
corwe*
- - JOMPH Q J42\ts wo
,, noene o.<.a .
{
.
DEPARTMENT OF HUMAN RESOURCES HEALTH OtVill0N neces veel He.iin secie.a 505 East King Street. Room 203 Carson City. Nevada 89710 (702) 885 5394 August 12, 1988 R. F. Burski, Manager Nuclear Safety & Regulatory Affairs Louisiana Power & Light 317 Baronne Street New Oricans, LA 70160 RE: 003-Q446-2-1, 003-Q446-3-1
.
Cear Mr. Burski Your letter dated August 4, 1988 is acknowledged. The letter described actions that will be taken to correct the violations documented during the recent inspection of LLW shipment no. 88-1010 from Louisiana Power & Light. The corrective actions were in response to violation numbers 003-Q446-2-1 and 003-Q446-3-1 cited in our letter dated June 30, 1988.
The corrective actions will be reviewed during future inspections to determine their effectiveness.
If you have any questions, please feel free to contact me.
Sincerely, A V I 4%nOot0
-
x R.' Marshall, Supervisor ha Ly Radiological Health Section Bureau of Regulatory Health Services lw2\lpivioltr cc: Bert Gray, Nevada Health Division Earl Ingersoll, State of Washington Virgil Autry, State of South Carolina Novelle Tucker, U.S. Dept. of Transportation Bill Spell, State of Louisiana
..
_. .. __
-
..,g. m ,c;c, ,,1 Ib 'L; c.N - .
. . .e
. .
t! CHARD Q. AfnAm STATE OF NEVACA e = LNORJWC1 P t:Atwfll As u.uu,,
Jtasy CalertNTR00 om JoltPH Q 4 Anis. 4 D
- n..o.s ca
.
- dC[lVED r ARVl5SWTIVE SUPp0FT
--
DEPARTMENT OF HUMAN RESOURCES MEALTH DM83084 '
SE: M T:39 a.u + w w e 6-a-ses t xus su t. n.. tos
-. ,, .
cat ee city, Nmde st7te tpg- f,* dC' "
.
(702) 845 5394 September 19, 1988 Chadi Groome Louisiana Power and Light company P.O. Box 60340 i Mail Unit N-17 New Orleans, LA 70160 Dear Ms. Groomel This letter is in response to the ree. test from your management concerning LLW shipments to the Beatty, NV Permit No. Q446 issued to Louisiana Power and Light Company.
site under Nevada Site User 'l l
Your lettern dated July 5, 1988, July 25, 1988 and August 4, 1988 :
to this office shipreents described to the the corrective actions for recent LLW Beatty site. Cur letters dated July 12, 1988, Augu:r !
L2 and August 13,1988 advised that the corrective actions would be
!
reviewed during future inspections of shippents frore Louisiana Power and Light company. I regret that our review of the corrective actions i and acknowledgments in writing were not interpreted by your manage: tent to include permission to resume shipments to the Beatty site.
You are advised that Louisiana Power and Light company is perraitted to resume LLW shipments to the neatty site. l
'
r i
I i
i l
l l
!
{
l l
I
..
I
! SEP 20 '88 12:01 '
__ -
- e ;tnio ee a:a at vr_ +c: e s : 22
.. ..
. .
,
If you have any further questions, please feel free to contact re.
Sincerely, stan R. P,4:shall, Supervisor Radiological Health section Bureau of Regulatory Health Services lw2\1pigrmeltr cca Bert Gray, Nevada Health Division Virgil Autry, State of South Carolina Earl Ingersoll, state of Washington Bill spell, state of Louisiana
.
I
.
1
.
SEP 28 '88 12:01 PAGE.002
.. ..
-
.
.
h l OUISl AN A / m NEA P OW E A & LiG H T eaacssistam . o ec,seu:
CALEANS LewS AN A 70160 . ($041 $95 P;c Y ii \l Us$~s July 5, 1988 V3P88-1631 A4.06 QA Mr. Stanley R. Marshall Department of Human Resources Health Division Radiological Health Section 505 East King Street, Room 203 Carson City, Nevada 98710 SUBJECT: Vaterford Steam Electric Station - Unit Number 3 Nevada Radioactive Waste Disposal Site User's Permit .
Number Q446 Low Level Waste Shipment Number 88-1008 REITRENCE: Department of Human Resources Letter from Stanley R. Marshall to dated June 7, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of the referenced letter indicating that two transportation-related violations were issued against LP&L's low level waste shipment number 88-1008. This shipment arrived at the Beatty, Nevada disposal site on May 31, 1988. The refer-enced letter was received on June 14, 1988, and requires a response within 20 days of receipt. As is discussed in detail below, LP&L bas reviewed the violations and has initiated corrective actions to prevent their recurrence.
Violation number 001-Q446-4-1 indicates that the placard on the front of the transport vehicle was placed within three (3) inches of the license plate b' older, ano therefore not in conformance with the requirements of 49CFR172.516(c)(4). Photographic documentation was included in the referenced letter to substantiate this finding.
Violation number 001-Q446-4-2 indicates that several portions of the carrier copy of the shippin8 manifest were not clearly legible, and
"AN ROUAL OPPORTUNITY EMPLOYER"
Pago '
- **
' *
. July 3, i900
.
therefore violated the requirements of 49CTR172.201(a)(2). This regu-lation specifies that:
The required shipping description on a shipping paper and all copies thereof used for transportation purposes, must be legible and printed (manually or mechanically)
in English.
LP&L was aware prior to the shipment leaving Waterford 3 that the carrier copy of the sanifest was not entirely legible, and tcok what it considers appropriate compensatory action. The manifest required by the disposal site is a five part carbon form, the last copy of which generally does not print clearly. As LPEL has been doing for quite some time, the first page of the manifest was photocopied and designated as the carrier copy in lieu of the last page of the five part manifest. In fact, both the State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned .
them about resolving the legibility concern. To avoid future confusion regarding which copies are used f ar transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest.
Radwaste Department Technical Procedure number RW-2-501, "Radioactive Waste Shipments" provides instructions regarding Department of Transpor-tation Nuclear Regulatory Commission and disposal site requirements for radioactive waste shipments. The procedure requires completion of checklists to insure that the proper paperwork and notifications have been completed, and that the shipeents and transport vehicles meet the applicable regulations prior to leaving Waterford 3. In light of these violations, the procedure has been reviewed, and is being revised to be more specific with regard to both placarding and shipping paper legibil-ity requirements. Approval of the chaeges is expected within the next two weeks, but in any case will be received prior to the next radioactive waste shipment. In addition, these vialationa and applicable regulatory requirements have been reviewed with personnel involved with radioactive waste shipments.
To insure timely responses, please address future correspondence to me.
My address ist P.O. Box 60340 Mail Unit N-17 New Orleans, Louisiana 70160
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _
- .
.. .. Pss2 3
,
- -
W3PS8 1631 July 5, 19e8
.
St.ould you require additional information regarding these violations, please contact Ms. Chadi D. Grocee at (504)$95-2846.
Very truly yours, gl,g...i R.F. Burski Nuclear Safety & Regulatory Af f airs Manager RTB/C3Gdsy cc: J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. Lalont'e, L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autry, E. Ingersoll, J. Hornor, B. Gray, Waterford 3 Records Center, Administrative Support (1), Licensing Library
_. . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _
.. ..
. .
f.O U181 POW AN AT E A & LIGH / mNEW eiacsse starir . o ecm :
CALEaNS Low $iaNA 701W . 6C4> $95 000
.
'$*U1s 5.%'O July 25, 1988 V3P38-1623 A4.06 QA Mr. Stanley R. Marshall Department of Human Resources Health Division Radiological Health Section 505 East King Street, Room 203 Carson City, Nevada 98710 SUBJECT: Waterford Steam Electric Station - Unit Number 3 Nevada Radioactive Waste Disposal Site User's Permit .
Number Q446 Low Level Vaste Shipment Numbers 88-1009 and 88-1011 RITERENCES: (1) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Vaste Shipment Number 88-1009 (2) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Vaste Shipment Number 58-1011 (3) Louisiana Power & Light company Letter W3P88-1631 from R.F. Burski to Stanley R. Marshall dated July 5, 1988 (4) State of Nevada Department of Human Resources Letter f rom Stanley R. Marshall to R.F. Burski dated July 12, 1988
Dear Mr. Marshall:
Louisiana Power & Light Company (LP&L) is in receipt of references 1 and 2 which describe transportation related violations issued against LP&L's low level waste shipment numbers 88-1009 and 88-1011 which arrived at the Beatty, Nevada disposal site on June 3, 1988 and June 6, 1988, respectively. As both violations are the same, they are being addressed together in this letter.
Also, we would like to note that these violations are the same as violation number 001-446-4-2 for which corrective action has been initiated, as described in reference 3 and acknowledged in reference 4.
.
"AN EDUAL OPPORTUNITY EMPLOYER"
0000 *
,. ., b3PS$.te23
. July 25, 1988
.
These two violations indicate that several portions of the carrier copy of the shipping manifests were not clearly legible, and therefore violated the requirements of 49CTR172.201(a)(2). This regulation specifies that:
The required shipping description on a shipping paper and all copies thereof used for trans e:rta tion purposes, must be legible and printed (sanually mechanically) in English.
LP&L was aware prior to the shipments leaving Wsterford 3 that the carrier copies of the manifests were not entirely legible, and took what it considers appropriate compensatory action. The manifest 'aquired Ay the dispossi site is a five part carbon form, the last copy of which p,onerally does not print clearly. As LP&L has been doing for quite some time, the first page of the manifest was photocopied and designated as the carrici copy in lieu of the last page of the five part manifest. In fact, both the State of Nevada Site Inspector and disposal site personnel suggested substituting photocopies for illegible carbon copies when LP&L questioned thee about resolving the legi-bility concern. To avoid future confusion regarding which copies are used for transportation purposes, any copies which may be deemed illegible and are replaced by photocopies will be removed from the manifest. ,
Radwaste Department Technical Procedure number RW-2-501, "Radioactive Waste Shipments" provides instructions regarding Department of Transportation, Nuclear Regulatory Commission and disposal site requirements for radioactive waste shipments. The procedure requires completion of checklists to insure that the proper paperwork and notifications have been completed, and that the
'
shipments and transport vehicles meet the applicable regulations prior to leaving Waterford 3. In light of these violations, the procedure has been revised to be more specific with regard to shipping paper legibility require-raent s . In addition, these violations and applicable regulatory requirements have been reviewed with personnel involved with radioactive vaste shipcents.
'
Should you require additional information regarding these violations, please contact Ms. Chadi D. Grocee at (504)595-2846. l Very truly yours. l
'
-
^
R.F. Burski Nuclear Safety & Regulatory Af f airs Manager RTBfW8/Isy !
cc J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. LaBonte.
L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.M. Spell, ;
V. Autry, E. Ingersoll, J. Hornor, B. Gray, N. Tucker, Waterford 3 Records Center, Administrative Support (1), Licensing Library !
l
- . - _ - _. _ . - -
.. ..
.
LOUl81ANA POWEA & LiG H T/ meAacss Starit . e o sex ecuo NEW C ALE ANS LOWS 1N A 70160 * (SC0 595 3t00 5'5511 dIsNO August 4, 1988 W3P88-1630 A4.06 QA Mr. Stanley R. Marshall Department of Human Resources Health Division Radiological Health Section 505 East Kinz Street, Room 203 Carson City, Nevata 98710 SUBJECT Waterford Steam Electric Station - Unit Number 3 Nevada Eadioactive Waste Disposal Sito User's Porait Number Q446 '
Low Level Waste Shipment Number 84-1010 RITERENCES: (1) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to dated June 30, 1988 Regarding Louisiana Power & Light Company Low Level Vaste Shipment Number 88 1010 (2) State of Nevada Department of Human Resources Letter from Stanley R. Marshall to Chadt Groome dated July 18, 1988 Dear Mr. Marshall Loutstana Po* er & Light Company (LP&L) is in receipt of the references letters discussing transportation-related violations issued against LP&L's low level waste shipment number 88-1010. This shipment arrived at the Beatty, Nevada disposal site on June 6, 1988. As is discussed in detail below LP&L has reviewed the violations and has initiated corrective actions to prevent their recurrence.
Violation number 003-446 2-1 indicates that contrary to 49CFR173.425(b)(1),
which requires that "Materials must be packaged in strong, tight packages to that there will be no leakage of radioactive material under conditions normally incident to transportation", package number 88 0111 was found to have a hole approximately 4 inch in diameter on the front of the package.
The violation continues that "No loss of container contents was found as a result of the hole in the package." While LPkL is not sintaising the seri-cuaness of a breach of integrity in a shipping package, it is important to note that this small hole did not result in leakage of radioactive materia *.,
and therefore the package sat the intent of the cited regulation.
"AN ROUAL OPPCMtTUNffY EMPLOYER"
_. ._ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.. ..
.
Page 2 W3P88 1630
.
As a result of this violation, LP&L has taken several steps to insure the integrity of its shipping packages. Packages already on site were reinspected.
Radwaste Department Technical Procedure numbers RW-2-501, "Radioactive Waste Shipments", and RW 2 300, "Receipt. Storage and Leading of Shipping Contain-ers", have been revised to clarify acceptance criteria and focus both receipt and final (prior to shipment) inspections on box integrity. Furthermore, while not a regulatory requirement for this type of container, procurement specifications have been upgraded to Quality Class II which imposes more stringent controls on both the vendor and LP&L.
Violation number 003-Q446-3 1 indicates that the subject shipment did not meet the requirements of 49CTR173.425(b)(6) snd 49CTR173.448(a) in that "the containers were found to have shifted to the front of the trailer as a result of the wooden wedges being released from between the containers during transit.
The release of the wedges created approximately 6 inches of space between the rear floor bracing saterials and the rear packages." The cited regula.
tions specify, respectively: ,
Shipment must be braced so as to prevent shifting of lading
,
under conditions normally incident to transportation.
and Each shipment of radioactive materials shall be secured in order to prevent shifting during normal transportation conditions.
In response to this violation. LP&L has thoroughly reviewed its loading practices and discussed the incident with personnel involved with radioactive ,
vaste shipments. gxtreme care was taken in preparing this shipment for transportation. The methods employed to secure the boxes should have been adequate to prevent the cargo from shifting to any appreciable degree, and an explanation of the loading procedures is in order at this time. The ship-ment consisted of ten boxes. The boxes were centered in the trailer, one behind the other, with the first box placed flush against the front wall of the trailer, and each subsequent bru abutting the box in front of it.
(secause the boxes bow slightly when full, the tops of the boxes could not be placed se,uarely against each other.) Yvo by fours were nailed to the floor of the trailer around each box to keep the boxes in place during transit.
A restraining device (a metal bar and ratchet mechanism) secured to the sides of the trailer (approximately three fourths up froc the bottom of the box)
was installed behind the fourth box to further inhibit movement and another was installed behind the last box to keep the cargo from moving backward toward the trailer doors. In addition, cargo straps were strung froe side *
to side in the t!ailer behind every other box. gecauge the boxes were slightly bowed and the tops could not abut, wooden wedges were driven between the boxes to further maintain the existing spacing and provide shock absorption.
_ _ ._ _
_ .
..
. .' - . ..
.
Page 3 W3P88-1630
.
Apparently some of these wedges vibrated free and gav ae aoraarance that the load may have shifted. As the wedges were not ne :n secure the shipment, they will not be used for future shipments.
As reference 2 rescinded violation number 003-Q446-3-2, the ed violation cited in reference 1, this violation does not require a r* .s e . However, LP&L wishes to point out that its efforts in investigating the violation identified the differences between the information presented in the viola-tiur, and LP&L's documdntation for the subject shipment. These differences were confirmed by the U.S. Ecology Site Radiation Safety Of ficer during a telephone call with LP&L personnel. The violation cites discrepancies between radiation levels measured at the disposal site and those indicated on the shipping manifest for three boxes. Two box numbers, 047 and 049, do nct match any box numbers on LP&L's manifest. Tite third box number, 0111, was indicated on the manifeat. However, the violation specifies that the
'
manifest indicated a radiation level of 800 mR/hr for this box, while the highest radiation level of any. box in she subject se peent was 500 mR/hr ,
contact. .As the documentation clearly indicates, these radiation level dis-a crepancies could not have been cited against the subject shipment, and LP&L appreciates your letter rescinding :his violation.
Should you require additional information regarding these violations, please contact Ms. Chadi D. Groome at (504) 595-2846.
Yours very truly,
. .
R.F. Burski Manager Nuclear Safety & Regulatory Affairs RFB/CDCIp1m cci J.G. Dewease, R.P. Barkhurst, N.S. Carns, P.V. Prasankumar, W.T. La3onte, J. Ridgel, L.R. Simon, D.B. Stevens, M.J. Meisner, G.E. Wilson, W.H. Spell, V. Autry, E. Ingersoll, J. Hornor, B. Gray, N. Tucker, Waterford 3 Records Center, Administrative Support. Licensing Library
-_ _ - . . _-
_. _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _
..'<..
.
DOCUNINTATION OF TELEPHONE COMMUNICATIONS
.
September 9, 1988 TIME: 1000 A.M. ggg, 7 ATE:
B.C. Morrison, C.D. Groome y PARTY CALLINC: J.A. Ridgel, L.R. Simon // LP&L (Name) p# (Company)
H.D. Chaney 0.E. Baer NRC. Region IV PARTY ANSWIRING:
(Name) (Company)
SUPJECT: IR 88-20 FILE: A7.09 QA
._
.-----.........................---........------------........--------------.....--.....--
.SUMHARY: (INCLUDING DECISIONS AND/OR COMMENTS)
-
.Chadi discussed the Nevada violations and indicated that all items had been taken care of. The NRC wants a summary of the problems and resolutions in a formal letter.
1 Chaney addressed the training response required by IR 88-20. He wants us to forms. ty document our commitment to IFB 79-19 items 5 and 6 and how we are going to keep the Radwaste Training up-to-date.
............. ... ....-------------------------------------------------------------------
ACTION RIQUIRED:
Chadi vill submit a letter on Nevada questions. Barbara and Marty Langen will i
prepare response to training question.
DISTRIBUTION:
Records Center Administrative Support, Licensing Library, Site Licensing Support File
- - - . . . - , - _ _. . _ .
_, ,. ._.
s s
, ,6 , e f* *W n UNITED STATES :
.
'
'
[ e\ NUCLEAR REGULATORY ^ '6 l f CEGloN IV ,
\ *, **** /r
, . til AYAN PLAZA DRIVE. bLlTC '900 .
ARLINGTON, TEXA5 *, ;11
- q g gy *ECEriED fr' ,
In Reply Refer To: r_ ADMINISTRATIVE SUPPORT Docket: 50-382/88-20 ggp 3 ygg Louisiana Power & Light Company E ' '
ATTN: J. G. Dewease, Senior Vice President .
Nuclear Operations 317 Baronne Street New Orleans, Louisiana 70160 i Gentlemen:
This refers to the inspection conducted by Mr. H. D. Chaney of this office during the period July 10-15, 1988. of activitios authorized by NRC Operating License NPF-38 for the Waterford Steam Electric Station, Unit 3, and.to the discussion of our findings with Mr. N. Carns and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included transportation o'f radicactive materials and low-level solid radioactive waste management. Within these areas, ;
. the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the NRC inspector. The inspection findings are documented in the enclosed inspection report.
Within the scope of the inspection, no violations or deviations were identified. !
.
However, we are concerned about the inactivity of your training program for radioactive waste (radwaste) workers and personnel involved in radioactive ;
satorial transportation activities. l
- Accordingly, you are requested to respond, in writing, within 30 days t,f the
' date of this letter, outlining steps taken to ensure that initial training and :
retraining programs are fully implemented for personnel in the onsite radweste l f
- group that satisfies NRC Inspectic's and Enf Atment Bulletin 79-19 commitments and current industry practices. Your respoM e .'hould address the root causes of l
'
why the previously established program wu allowed to become inactive, and the short and long ters actions to be taken to improve and maintain the training i program in the future.
One unresolved item is identified in paragraph 8 of the enclosed inspection
-
i report. : i
! !
The response directed by this letter is not subject to the clearance procedures i
of the Office of Management and Budget as required by the Paperwork ReductioT)
!
Act of 1980, PL 96-511.
'
!
,
,
l YuffYS~ . - - _ _ _
,,$yf, _ _ _ _ _
'
..e>..
.
Louisiana Power & Light Company -2-
.
.
Should you have any questions concerning this inspection, we wil. be pleased to discuss them with you. ,
Sincerely,
'
t,dw Lt)
/ Division L. J. Callan, Director of Reactor Projects
Enclosure:
Appendix - NRC Inspection Report 50-382/88-20
REGION 'V NRC Inspection Report: 50-382/88-20 Operating License: NPF-38
~
Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)
317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 (WAT-3)
Inspection At: WAT-3 site, Taft St. Charles Parish, Louisiana Inspection Conducteti: July 10-15, 1988
\
Inspector: b'- 7 8 17 H. D. Chade M ladiation Spec 7alist, Facilities Date Radiological Protection Seg: tion Approved: dM7 M R.'E. Baer, Chief, Facilities Radiological Date Protection Section Inspection Sunnary Inspection Conducted July 10-15, 1988 (Report 50-382/88-20)
Ar_eas Inspected: Routine, unannounced inspection of transportation of radioactive materials and low-level radioactive waste (LLRW) management.
Results: Within the areas inspected, no violations or deviations were identified. One unresolved item concerning the transportation of radioactive materials tras identified (see paragraph 8).
.
i
. . ' . .
.
'
.
DETAILS 1. Persons Contacted .
LP&L
- N. Carns, Plant Manager
- S. Alleman, Quality Assurance Manager F. Davis, Nuclear Operations Support and Assessment Engineer G. Espenan, Nuclear Operations Support and Assessment Engineer R. Kenning, Nuclear Operations Support and Assessment Engineer
"W. LaBonte, Radiation Protection Superintendent J. Ladet Security Supervisor, Operations
- M. Langan, Tuchnical Support Training Supervisor D. Landeche, Health Physics (HP) Supervisor .
M. Marler, HP Trainer R. McLendon, Dosimetry Supervisor
- P. Prasankumar, Assistant Plant Manager, Plant Technical Services S. Ramzy, Assistant Radiation Protection Superintendent
"J. Ridge 1, Assistant Radiation Protection Superintendent
-
- 0. Stevens, Radwaste Supervisor Others
- T. Staker, NRC Resident Inspector
- Denotes attendance at the exit interview.
The NRC inspector also contacted other licensee personnel including administrative, security, and quality assurance (QA) personnel.
2. NRC Inspector Observations The following are observations that the NRC inspector discussed with the licensee during the exit interview on July 15, 1988 and (observation b.
which was discussed with R. Kenning) by phone on July 19, 1988. These obse';>vations are not violations, deviations, unresolved items, or open items,. These observations were identified for licensee consideration for program improvement, but the observations have no specific regulatory requirement. The licensee stated that the observations would be reviewed (no comunitment was made in regard to observation b.). .
a. Clean Waste Release - The procedure currently in use for the testing of gansna scintillation counting of bulk paper and plastic wastes to be released for unrestricted use is not signed or dated.
i
,
..*"..
^
.
b. Radwaste proaram Assessments - Neither the Corporate Nuclear Support Services Section nor the onsite Operations Support and Assessment Group routinely performs assessments on low-level solid radwaste'and transportation activities.
.
3. Open Item Identified Durina This Inspection An open item is a matter that requires further review and evaluation by the NRC inspector. Open items are used to document, track, and ensure adequate follow-up on matters of concern to the NRC inspector. The following open item was identified:
Open Item Title See Paragraph 382/8820-01 Retraining of Radwaste Staff 6 4. Unresolved Item Identified Durina This Inspection An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable ites, a deviation, or a violation.
The following unresolved item was identified:
Open Item Title See Paragraph 382/8820-02 State of Nevada Identified 8 Transportations Regulation Violations 5. Organization and Manaaement Controls - Transportation /Radwaste (83522/83722)
The NRC inspector inspected the licensee's staff assignments including:
organization, assignment of responsibilities, authorities, staffing, identification and correction of problems, audits and surveillances, commurication to employees, documentation and implementation relating to radioactive affluents and solid wastes, and the transportation of radioactive materials to determine adherence to commitments contained in Sections 11 cand 13 of the Updated Final Safety Analysis Report (UFSAR),
and NRC Inspection and Enforcement Bulletin (IE8) 79-19 and compliance with Technical Specificatinn (TS) 6.2, 6.8, and 6.13.
The NRC inspector reviewed the organization of the licensee's radwaste department which is responsible for management of solid radioactive waste processing and transportation of radioactive materials (RAM). The NRC inspector also reviewed the LP&L Corporate support (Nuclear Support Services Section) provided the WAT-3 radweste program. -
The NRC inspector reviewed the licensea's senior management policies (Nuclear Operations Management Manual), which included the assignment of responsibility for AAM shipments, implementing procedures for control of LLRW processing and transportation of RAM, the NRC approved Process
. . ~ , .
.
-
<
Control Program (PCP) (Procedure RW-01-210), field quality control activities, and the NRC approved QA program (Docket: 71-0604) for transportation activities. The licensee utilizes an ancillary speciaT scope QA program in conjunction with their 10 CFR Part 50, Appendix B, QA program for ensuring quality in RAM transportation activities. Procedures and other documents reviewed during the inspection are listed in the Attachment to this report.
The NRC inspector reviewed the licensee's audit program includi.ig current and planned audits for LLRW and RAM transportation activities. The following audits and survelliances were reviewed:
' Surveillance QS-88-055, Purchase Orders and Receipt Inspection of Shipping Packages
Audit SA-87-024.1, Radwaste Processing
Audit SA-87-003E.1, Radwaste Training and Qualification
- Audit A39.356-87.1, Container Products Corporation (Vendor Audit)
The licensee's audits were found to be comprehensive and included an adequate amount of performance based objectives. The NRC inspector noted that while the Nuclear Operations Support and Assessment (NOSA) Group performed operational assessments on most other activities at WAT-3, N0SA does not perform assessments in the area of radwaste operations.
No violations or deviations were identified.
6. Trainina and Qualification - Transportation /Radwaste (83523/83723)
The NRC inspector reviewed the licensee's training program including adequacy of training, employee knowledge, qualification requirements, position descriptions, technician, contract technician screening and training, audits, and training not covered by INPO accreditation to determine agreement with cosnitments in Section 13.2.2.8 of the UFSAR, and NRC IEB 79-19, and compliance with the requirements of Technical Specification (TS) 6.3 and 6.4.
The NRC Inspector observed work practices and interviewed radwaste group personnel. The licensee's biennial requalification program for personnel involved in radwaste processing and transportation activities was reviewed for adequacy. Training records for the plant staff (approximately .
21 radwaste and HP individuals) involved in the processing and transportation of RAM were reviewed for completeness. The NRC inspector also reviewed the licensee's implementing procedures and lesson plans for the training of radwaste personnel. The NRC inspector noted (this was also identified during a QA audit) that at least four radweste personnel
'
have not received any formal radwaste training since hiring on at WAT-3.
None of these persons appeared to have performed radwaste processing activities other than collection of waste. The last training for many l
..*4 .
.
.
radwaste personnel was the completion of on-the-job training checklists in 1986. The NRC inspector noted that the licensee had provided many individuals with required reading of procedural changes and vendor provided training on radwaste and transportation activities in 1986 and 1987 which satisfies the biennial requalification requirements. The NRC inspector also noted that the lesson plans for the radwaste training program were not current (1984 vintage) in the areas of regulatory requirements and licensee facilities. The iicensee training program for radwaste workers was an item of concern in N9C Inspection Report 50-382/85-26 ~and resulted in the issuance of a Notice of Violation (NOV) for the failure to ensure that a contract worker received proper training. This area was strengthened as a result of the NOV. The Nuclear Training Department (NTO) staff positions responsible for radwaste group training activities have had a high turnover rate in the past which has resulted in the program not being maintained in a current status. The licensee's NTO had filled the vacant position of instructor for the radwaste group around July 1, 1988. The licensee's radwaste training program will be considered an open item pending licensee implementation of
,
an upgraded training and requalification program for radwaste workers (382/8820-01).
No violations or deviations were identified.
7. Solid Radioactive Waste (84522/84722)
The NRC inspector reviewed the licensee's program for the control, classification, characterization, and shipment of low-level radioactive waste to determine agreement with the commitments contained in Section 11 of the UFSAR and compliance with the reoufrements contained in TS 3.11.3, 4.11.3; 10 CFR Parts 20.301, 20.311, 61.55, and 61.56; and the recermendations of NRC Branch Technical Position (BTP) papers on LLRW classification and waste form.
The NRC inspector reviewed the licensee's computerized program for management of waste processing and packaging activities (RADMAN). The licensee's biannual evaluation of waste streams and development of isotope correlation factors were reviewed. The licensee's LLRW characterization and classification program is well documented. The NRC inspector reviewed the licensee's vendor provided processes for dewatering of filters and resins. The licensee's PCP and the licensee's vendor's FCP for the processing of various waste streams were reviewed for management control over changes and revisions. The NRC inspector reviewed selected records of waste processing activities (resin solidification, filter dewater.ing, dry active waste compaction, and oil solidification) for 1987.
The NRC inspector reviewed the licensee's records for LLRW shipped since 1985. The following tabulation shows the total volume of LLRW shipped for the 1985 through 1987.
l
. >* =oo e
.
Volume Shipped (Cubic feet)
Year Goal Actual Curie Content 1985 5,000 9,997 33.5 ~
1986 6,227 6,138 37.5 1987 8,000 13,330* 178.2
- Included approximately 5,000 cubic feet of boric acid concentrator bottoms held over from 1985 due to licensee efforts in evaluating onsite burial.
No violations or deviations were identified.
8. Transportation (86721/86740)
The NRC inspector reviewed the licensee's program for transportation of RAM, program audits, procurement and evaluation of packaging, determination of package activity, preparation of packages for shipment, maintenance of packages, delivery of packages to carrier, and the receipt of RAM for compliance with the requirements of 10 CFR Parts 20.205 and 20.311; 10 CFR Part 71; and Department of Transportation (DOT) regulations (49 CFR) incorporated by 10 CFR Part 71. ,
The NRC inspector reviewed 30 shipping records from the 1986 and 1987 period for completeness and accuracy. The licensee's authorization to utilize specific shipping packages was verified. The NRC inspector reviewed the documentation including advanced notification, package opening and closing checklists, hazardous waste manifests, sole use instructions, and survey records. The NRC inspector noted that the licensee routinely used extensive checklists for accomplishing shipments of RAM.
The NRC inspector was informed, on July 11, 1988, by the licensee, that LP&L had been notified by the state of Nevada that several violations of DOT and burial site requirements had be identified during inspection of two of the licensee's waste shipments to the Beatty, Nevada, burial site
(May 1988, Radioactive Shipment Record (RSR) 88-1008 and June 1988, RSR 88-1010). The violations identified by the state of Nevada included radiation dose rates on waste containers significantly greater than shipping records indicated, a waste container (strong tight package for low-specific-activity shipment (s)) was found to have a %-inch hole in it (manufacturing defect), improper location of DOT required placard, illegible manifest copies, and the bracing used in a sole-use enclosed <
trailer-van came loose and allowed the load to shif t. The 1.icensee had not fully investigated each of the apparent violations at the time of this inspection. The licensee had instituted an immediate inspection of waste containers used for the shipment of dry active waste (OAW). The licensee determined that several of the onsite ready for use Container Product Corporation's B-25 containers (steel boxes of approximately 95 cubic feet l
capacity) contained manufacturing defects. These containers are not
! required to be DOT approved or NRC certified. The hole in the B-25
. _ _ _ - - .
.>=%.
, .
l l
container, founo by the state of Nevada, was the result of a weld burn-through that was painted over at the manufacturing facility and was not readily identifiable during the licensee's proceduralized preuse ,
inspection of the container. At the time of this NRC inspection, the licensee had already instituted corrective actions concerning potential -
defects in waste containers used for DAW packaging and had revised their receipt inspection program for strong, tight containers of all makes. The licensee informed the NRC inspector by telephone on July 18, 1988, that preliminary investigation of the apparent high dose rates on waste containers may be the result of a state of Nevada mix up involving another shipper's material and not LP&L's. NRC enforcement will be deferred until all of the state of Nevada's violations have been resolved. The licensee's apparent violation of NRC and 00T regulations will be considered an unresolved item pending further review by the NRC during a future inspection (382/8820-02).
The NRC inspector noted that the licensee's QA department had just completed a surveillance of waste packaging procurement and receipt inspection. The draft results of the surveillance indicated that several deficiencies were identified in the licensee's program for these materials.
The licensee had not experienced any transportation incidents which caused a reduction in the effectiveness of an NRC or 00T certified packaging since the previous inspection.
No violations or deviations were identified.
9. Review of Periodic and Special Reports (90713)
The NRC inspector reviewed the licensee's semiannual effluent reports for 1986 through 1987 for compliance with the requirements of TS 6.9.1.8, 6.13, and 6.15 and the recommendations of RG 1.21.
The licensee's semiannual reports for the years 1985, 1986, and 1987 were reviewed and compared to the licensee's docuser.tation concerning radioactive material shipments (solid LLRW disposal), PCP changes, and modifications to the solid LLRW processing systems.
No violations or deviations were identified.
10. Exit Interview ,
The NRC inspector met with the NRC resident inspector and licensee representatives denoted in paragraph 1 on July 15, 1988, and sussiarized the scope and findings of the inspection as presented in this report. The licensee agreed to provide the NRC with all correspondence involving the state of Nevada's 1988 inspection and enforcement actions concerning LP&L.
.v~..
. . - . e ._ . a
.
v. r .t. i . :ugss.r m sE o 1 56-:s213 .'
.
,.
k.OCUqE.rqf,,pg'.'I_gWED 117bF EE*fIS,ICU
D 7E rE : 1 c er .oppr a.t t ent _ tipnagement Man.v1 .
.
-cction !.
. Special Sco.'e Ovalits Fo11ctes Chapter 5. Radioactise Weste Management 3 12-!1-87 4100 ! 2C'2C t t LW g _ Mg gu131,
ul ume 20. Radioacti ve Waste Manaoement F r oc edur es
.
R W - 01 - 1 '." . Radioactive Waste Reduction 2 00-18-67 RU-01-2OO. Record Prop ration. Filino, and Storage 1 06-2s-87 RW-01-210. Process Control Program 2 07-10-87 RW-02-100. Waste Material Collection and 4 03-25-88 Handlino RW-02-110. Waste Sample Collection and Isotope Evaluation 3 05-18-87 RW-02-120. Handling Used Protective Clothing O 07-14-86 RW-02-2OO. Packaging Radioactive Solid Waste (DAW) for Disposal 5 08-20-86 RW-02-210. Radioactive Waste Solidificction 6 10-26-07 RW-00-020. Radwaste Filter Disposal 2 01-07-86 RW-00-030. Waste Material Segregation 3 06-20-88 RW-02-231. Granulating Material for Disposal 2 03-29-88 RW-02-240. Blowdown Dominerali:er Resin O 04-07-86 Transfer RW-02-3OO. Receipt. Storage and Loading of Shipping Containers 2 05-23-06 RW-OO-310. Storage of Loaded Shipping 3 09-15-86 Containers RW-02-320. Packaged Radioactive Waste Control and Inventory 5 06-06-87 RW-00-330. Radioactive Waste Tracking 1 02-18-86 RW-02-401. Use of Radman Operating Program O 08-07-87 RW-02-411. Use of Radman Data Manager O . 09-10-87 RW-02-420, Operation of the Filtrk Computer 05-04-87 Pr-ogr am O RW-02-430, Operation of the RAMSHP Computer 06-01-88 1 i Program .09-15-87 !
RW-02-500. Radioactive Material Shipment 3 RW-02-501. Radioactive Waste Shipment 1 04-08-88 RW-02-521. Type and Guantity Determination O 05-05-87 RW-02-530. Decay Heat Calculations for
-
O 05-05-87 l USNRC Certified Containers O 05-04-87 RW-02-541. Hydrogen Gas Calculation 1 02-18-86 RW-02-800. Dose to Curie Conversion 02-18-86 RW-02-810. Waste Classification 1
_ _ __ _ ___
s w c% .
r,'t- .., li'D . 3
.
L.r t.e,r. r: a s .. . 9
,
se j - i l ? . LN T echnvi cc,1 c u F r u s 2 ,, Corit e c)
.
F - o. .c e ni for Dco,t er a no Linces G '. m. n o. .-
W-Ont. LN T ertiriol oo t er F r'oce s s Cori'.* v1 F roce an. f e,r R a dw;ii t e 2:o11 d i f i c.a t t on 6 05--O" - F 7
- - e G. Oinir tinu F- r or. ? .f u r e f or- LN Tec tint..l oo t er, Radwe E,t e Solldificat2cn 3.su.. #6506 -
G U .l news, Nr C Appr o.od Topic 1 Fsport PS-52.-6076.
fJUS Redwaste So11 di f i cat t ore Svstem -
05-70-85 Nug j.rjar , Tr a i n,1 ng ,Dqgett ment _F rgc.edyrys (JTC ~57. Radweste Services Trainino Fracram 2 64-07-38 LW5fD0_EL20F T000-000-01. Radwaste Helper Final Exam 1 01-03-96 TOCl-000-01. Radwaste Helper -
Radwaste Frogram Overview 1 09-26-84 T001-001-00. Radwaste Helper -
Nuclear Power Orientation O 09-28-84 T001-002-00. Radweste Helper -
WAT-3 Radwaste Systems G 09-28-84 T002-000-01. Radwaste Helper -
Solid Radwaste
- Compaction 1 09-28-84 T003-OO6-61. Radwaste Helper -
Radwaste Solidification 1 09-28-84 W3TOO4-OOO-OO. Radwaste Helper - Radioactive Material Classification and Qualification 1 04-18-80 W3TOO4-001-00. Radwaste Helper - Radioactive t
Material Packaging - 04-18-83 W3T004-002-00. Radwaste Helper - Marking.
Labeling. Placarding Requirement for Shipments - 04-18-83 W5T005-000-00. Radwaste Helper - Radioactive - 04-19-83 Material Shipping Papers T017-000-00. Radwaste Helper - Radioactive 09-28-84
' Shipments O 7018-000-00, Radwaste Helper - Dry Waste 03-11-85 Segregation 0 0 08-30-84 c
T901-OOO-00. Radman Software 00:Iberdek_ Ice 1010e_Gbesklists ~
- 05-02-86 T501-000-00. Basic Radwaste 09-08-86 T506-000-01. Radwaste Equipment Operation -
05-02-86 T502-000-00. Handling and Control of DAW -
05-02-86 i T503-000-00. Packaging of DAW -
T510-000-00. Radioactive Material /Radwaste - 05-02-86 Shipping - 07-30-86 T511-OOO-00. Contract Decon Technician Quals
- - __
-lvsb&
-
.. ,,c a e..:.;. ea r..w i + a n a i + .; c ., r t
.
.
. . r o.o n o. .-
.
Crien -rave j e,r C a s l. 14-195H. CertC .=4
. Cho.n-fJucl ear C ast 6-100B. CofC i:-e .
Ltd lechnoloot es Cast US//5151e".. CotC 51 ,1 fJU$ Ces6 7-10Q. Co+C 4000
-
- L 1 c e954e _G 9CC MP.20(1905e Develle s LF t.L ) to file. Subjects-"1E Iriter-0+ f t re Corresoorsdencat. S.
- Bullet.tn 79-19. Fact +9tng of Low-Level Radioactive Waste for Transoort and bur 1al". deted Julv 19 1785. Ser1e1 tJo. WOF83-2488
e
.
.
.
e
- a O
e
. 3