IR 05000245/1987008

Insp Repts 50-245/87-08,50-336/87-08 & 50-423/87-06 on 870309-13.No Violations Noted.Major Areas Inspected:Licensee Action on Previously Identified Items,Including Solid Radwaste Classification,Handling & Transportation

ML20213A437
Person / Time
Site:	Millstone
Issue date:	04/15/1987
From:	Pasciak W, Struckmeyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213A434	List: IR 05000245/1987008 ML20213A432
References
50-245-87-08, 50-245-87-8, 50-336-87-08, 50-336-87-8, 50-423-87-06, 50-423-87-6, NUDOCS 8704280011
Download: ML20213A437 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-245/87-08; 50-366/87-08; 423/87-06

' Docket No ; 50-336; 50-423 License Nos. OPR-21; DPR-65; NPF-49 Priority --

Category C Licensee: Northeast Nuclear Energy Company P.O. Box 270 HE tford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station, Units 1, 2 and 3 Inspection At: Waterf.-d, Connecticut Inspection Conducted: March 9-13, 1987 Inspector: [ _ p -

Richard K. Struckmeyer, 8k61ation Specialist V/f/p?

/ d6te Approved by: . na Walter J. Pasgia), Chief, Effluents S '/fl5f27

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Radiation Protection Section, EPRPB Inspection Summary: Inspection conducted March 9-13, 1987 (Combined Inspection Report Nos. 245/87-08; 336/87-08; 423/87-06)

Areas Inspected: Unannounced inspection of licensee action on previously identified items in the following areas: solid radioactive waste classifica-tion, handling, and transportation; radiological environmental monitoring; radiochemical analysis; and chemistry quality control progra Results: Of twenty-five items reviewed, twenty-two were closed. No new items were identified, i

8704290011 870417 PDR ADOCK 05000245 O PDR

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DETAILS i 1.0 Individuals Contacted

• R. Asafayto, Quality Services Supervisor, NNECO

• G. Clostus, QA/QC Supervisor, NNECO J. Doroski, Senior Engineer, RAB, NUSCO

• B. Granados, HP Supervisor, MNGS

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T. Ittelaig, Assistant Chemistry Supervisor, Unit 2

• J. Kangley, Radiological Services Supervisor, MNGS J. Keenan, Superintendent, MNGS Unit 2

*J. Laine, Radiation Protection Supervisor, Unit 2

• F. Libby, Jr., Supervisor, Operations QA, NUSCO

• S. Scace, Station Superintendent, MNGS

• H. Siegrist, Supervisor, Radiological Protection, NUSCO J. Stetz, Superintendent, MNGS Unit 1 3 P. Strickland, Supervisor, Chemistry /HP Training, NNECO

• J. Sullivan, Radiation Protection Supervisor - Radiological Materials i Handling i

• J. Waters, Chemistry Supervisor, NNECO D. Wilkens, Assistant Chemistry, Supervisor, Unit 1

• Indicates those attending exit meeting on March 13, 1987

2.0 Licensee Action On Previously Identified Items 2.1 (Closed) Violation (245/85-03-01; 336/85-04-01) Excessive free ,

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standing liquid: The inspector reviewed the licensee's corrective action, which consisted primarily of revising the Millstone Station Inspection Plans (for shipments of radwaste) to add a requirement for

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inspection for free standing liquid. These revised plans, which were effective February 24, 1985, are applicable to the following shipping

, casks: NUPAC OH-142, CNSI 8-120A, CNSI 8-1208, CNSI 14-190H, and CNSI l 21-300/14-195H. There have been no known recurrences of excessive

free standing liquid in radwaste shipments from Millstone station to

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burial site ! 2.2 (Closed) Inspector Followup Item (245/85-05-01; 336/85-06-01; 423/85-07-01) Negative bias in QA air particulate filter results and

, in QA TLD results: The inspector reviewed the licensee's efforts to

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reduce the bias evident in the results of these QA samples. With regard to the QA air particulate filters, procedure ES 512 now specifies an improved method for preparing the spiked sampl In addition, a licensee audit of its contractor lab identified another contributing factor pertaining to the efficiency of the instrument used in the measurement of radioactivity on the filter. With regard to the QA TLDs, the licensee placed a new TLD reader in service in October, 198 Results in 1985 and 1986 have improved, especially for field TLDs. Spiked TLDs still exhibit a negative bias, although to a lesser extent than in previous years. The license stated that the reasons for this bias are still under investigation, and that i

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work on this problem will continue, and will be tracked in the minutes of meetings held between NUSCO RAB and its laboratory (POSL).

2.3 (Closed) Inspector Follovup Item (245/85-05-02; 336/85-06-02; 423/85-07-02) Update training records for NUSCO personnel involved with Radiological Environmental Monitoring Program: The appropriate

, RAB personnel have received training in procedures pertaining to

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this program. In addition, procedure RAB 1-1 was revised to indicate the need for supervisors to ensure that personnel are retrained when any REMP procedures are revise .4 (Closed) Inspector Followup Item (245/85-05-03; 96/85-06-03; 423/85-07-03) Modify procedure ES-002 to specif> visual verification of trainee's ability in sampling techniques: The inspector verified that the procedure was revised to include this requirement.

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1 2.5 (Closed) Violation (245/85-09-01; 336/85-11-01) Oose Rate on Package

, exceeded 200 mr per hr: The licensee developed procedure RW l 6012/26012/36012 " Packing Non-Compactible LSA Containers," which requires that no item having a dose rate of more than 160 mr per hr on contact may be placed into an LSA container. Any compactible material with a dose rate of more than 160 mr per hr on contact will l be placed in a 55 gallon drum. The Radiological Materials Handling l Department has been reorganized; the " Radiation Protection Supervisor - Radiological Materials Handling" now reports directly to the station Health Physics Supervisor. Radwaste shipping records are reviewed by the RPS-RMH, the HP Supervisor, and the Station Services Supervisor. There have been no known recurrences of excessive radiation levels in radwaste shipments from Millstone station to burial site .6 (Closed)InspectorFollowupItem(245/85-11-01;336/85-14-01) Review

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training of Senior Radiation Protection Technician acting as l Radiological Materials Handling Supervisor (RMHS): The senior radiation protection technician no longer assumes the duties of the RMHS. The licensee has reorganized its Radiological Materials Handling Department. The positions of Radiation Protection Supervisor - Radiological Materials Handling (RPS-RMH) and an assistant RPS in this area were created. The RPS-RMH reports to the station Health Physics Supervisor, and is at the same level of

management as the Radiation Protection Supervisors for each of l Millstone Station's three operating units. In the absence of the RPS-RMH, the assistant RPS in this group will assume the

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responsibility for approval of radwaste shipments. Additional l personnel have been hired as radiological materials handlers.

I Training of personnel involved with radwaste handling is further discussed in paragraph 2.1 .7 (Closed) Inspector Followup Item (245/85-11-02; 336/85-14-02) Review training of corporate auditors reviewing transportation area: The

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inspector verified that corporate auditors were among the personnel who received training in various areas related to radioactive waste classification, packaging, and shipping. Training is further discussed in paragraph 2.1 QA Audit No. A60436, performed 9/16/85

- 10/21/85, included an individual with technical expertise in this area to assist the lead auditor. Subsequent audits have been performed using auditors with training in the radwaste are ,

2.8 (Closed) Inspector Followup Item (245/85-11-03; 336/85-14-03) Review shipping records for " stand alone" completeness: The inspector reviewed selected records of shipments and determined that all the required paperwork was kept together. The licensee has begun using form SF 625, " Paperwork Checklist for Radioactive Shipment," to help ensure that all relevant documents are brought together into the file for each shipment. Also see paragraph 2.2 .9 (Closed) Violation (245/85-11-04; 336/85-14-04) Failure to follow procedure for QA inspections under Technical Specification 6.8: The licensee developed a new procedure, ACP-QA-2.018, which has since been revised to ACP-QA-2.01A, Rev. 2. This procedure, entitled

" Radioactive Material and Waste Packaging, Shipping and Processing Quality Assurance Program," specifies how and to what extent the QA program applies to preparation of radioactive waste for shipmen The specific issue in this case was lack of a receipt inspection by QA for equipment to be used in preparation of radwaste for shipment. This issue is addressed by section 6.7.2 of ACP-QA-2.01A, which states that "The Health Physics Supervisor shall ensure a program is developed that ... ensures material, equipment and services purchased for use in radioactive shipment preparation and transport conforms to procurement documents in accordance with ACP-QA-4.02." The latter actually consists of two procedures:

Procedure ACP-QA-4.02A incorporates Nuclear Engineering and Opera-tions group (NE0) procedure 6.02 (" Preparation and Review of Quality Related Purchase Requisitions") in its entirety. Procedure ACP-QA-4.028 is entitled " Receipt, Control and Identification of QA Material."

2.10(Closed)InspectorFollowupItem(245/85-11-05;336/85-14-05) Review upgrade of QC/QA program to monitor transportation activities: The licensee now performs " activity observations" in accordance with pro-cedure ACP-QA-9.07A, " Quality Activity Observation Program." The inspector reviewed copies of the activity observations of the rad-waste area performed in 1986 and 1987; these observations covered various activities related to radioactive waste handling, including transfer of spent resins to a liner; resin solidification; procedural compliance with NE0 6.07; waste compaction; and preparation of a shipping cask prior to loadin .

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The inspector also reviewed audits of the licensee's radwaste program: NUSCO Audit A60482, " Millstone Station Radwaste Transpor-tation & Packaging," (September 8 - October 8, 1986). The auditors identified six findings and two unresolved open items. A Millstone Health Physics Audit, conducced August 20-21, 1986, and documented in memorandum NE-86-RA-928, identified one deficiency. The licensee has completed its actions on all but two of the NUSCO Audit findings, and the responses to these have been accepted by QA; however, the items have not yet been formally closed. The item from the Health Physics audit has been close .11 (Closed) Inspector Followup Item (245/85-11-06; 336/85-14-06) Review corporate QA procedures for correction of confusion on applicability and acceptance criteria for transportation: The licensee developed a new procedure, ACP-QA-2.018, which has since been revised to ACP-QA-2.01A, Rev. This procedure, entitled Radioactive Material and Waste Packaging, Shipping and Processing Quality Assurance Program," specifies how and to what extent the QA program applies to preparation of radioactive wasto for shipment. This procedure references ACP-QA-4.02A, which discusses procurement of Category I items and services for radsaste systems and radioactive material shipments. Procedure ACP-QA-2.01A also includes instructions to the Health Physics Supervisor to ensure that acceptance criteria are satisfied. The inspector reviewed selected radwaste handling and shipping procedures, and noted that acceptance criteria have been incorporated as appropriat .12 (Closed) Inspector Followup Item (245/85-11-07; 336/85-14-07) Review QA audit team qualification in transportation areas: The licensee's response to 245/85-11-02; 336/85-14-02 is sufficient to close this item as well. Training is further discussed in paragraph 2.1 .13 (Closed) Inspector Followup Item (245/85-11-08; 336/85-14-08) Review QA monitoring of transportation activities: The inspector reviewed several " activity observations" performed in 1986 and 1987, as well as the audit conducted by corporate QA in September-October 198 Another audit was performed in September-October 1985. The frequency and scope of QA monitoring of radwaste transportation activities has improve .14 (Closed) Inspector Followup Item (245/85-11-09; 336/85-14-09) Review radwaste shipping procedures for step-by-step instructions and acceptance criteria: The inspector reviewed selected radwaste shipping procedures and determined that acceptance criteria generally are included in the revised procedures where appropriate. In addt-tion, procedures 6003/26003/36003 and 6005/26005/36005 have been revised to provide step-by-step instructions pertaining to 49 CFR requirement l

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2.15 (Closed) Inspector Followup Item (245/85-11-10; 336/85-14-10) Manage-ment oversight of packaging and transportation activities: The licensee's Radiological Materials Handling group has undergone reorganization twice since this item was identified. Under the present organization, the assistant Radiation Protection Supervisor

- Radiological Materials Handling (RPS-RMH) would assume the duties of the RPS-RMH in the latter's absence. The inspector verified that Radwaste shipments are now reviewed by the RPS-RMH, the station Health Physics Supervisor, and the Radiological Services Superinten-dent. The inspector also reviewed the licensee's commitment to reactivate its Radwaste Review Committee (RRC). The inspector reviewed selected minutes of RRC meetings held in 1985, 1986, and 1987. These meetings have been held at intervals of approximately three to six month .16 (Closed) Inspector Followup Item (423/85-42-01) Review training and qualifications of NNECO and contractor chemistry technicians: This item consisted of two issues. The first concerned refresher training for NNECO chemistry technicians who had not passed exams given in training courses. The licensee stated that in the future, a techni-cian will be entitled to three chances to take an exam in a given area. If the technician has not passed the exam after three tries, he/she will no longer be permitted to work as a chemistry technicia The second issue, regarding training of contractor chemistry technicians, was addressed in an internal memo from the station superintendent to the Director of Nuclear Training, NUSCO. This memo stated that contractors should be trained to the degree necessary for the function and duties they will be required to perform independently. Those contractors who are to remain at the site longer than 6 months, or who will work on Category I systems, or will independently perform critical tasks such as chemical analyses, should in general be trained to the same technical level as the regular plant staf .17 (Closed) Inspector Followup Item (423/85-65-01) Review results of chemistry and vendor laboratory capability tests: Samples prepared by the Department of Energy Radiological and Environmental Sciences

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Laboratory (RESL) were sent to the licensee following inspection 85-6 During this inspection, the results of the analyses of these samples were compared to the known values supplied by RESL. The results of this intercomparison are given in Table I. The results indicate that three of the measurements were not in agreement under the criteria used for comparing results (see Attachment I). Two of these measurements were analyses of tritium performed by the licensee's laboratory. As shown in Table I, the licensee's results were conservative, in that they overestimated the amount of tritium present in the sample. Table I also indicates that the vendor laboratory's analysis of Fe-55 resulted in an overestimate of the amount of this radionuclide in the sample. Because of this

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7 conservatism, no immediate corrective actions are necessary. A subsequent check of the licensee's capability to correctly analyze for tritium and Fe-55 will be conducted in a future inspectio .18 (Closed) Inspector Followup Item (423/85-65-02) Chemistry (Unit 3)

to reference vendor lab QC program in its QA procedure: The inspector reviewed revised procedure CP 3800 " Chemistry Quality Assurance Program" (Rev. 2,11/6/86), and determined that this procedure now contains the appropriate reference to the vendor QC program, in which QC samples (spikes, splits, duplicates, etc.) are prepared by the licensee and sent to the vendor laboratory for analysis. At the present time, the QC program is the same for all three units at Millstone statio .19 (0 pen) Violation (245/86-06-01; 336/86-06-01) Package not labeled properly: The licensee attributed the cause of this problem to be insufficient training of personnel with regard to D0T regulation Additional training has been provided, primarily by contractor organizations, to persons involved in the transport of radioactive material. The inspector noted that the personnel who received this training included radioactive materials handlers and supervisors, as well as QA and QC personne The licensee has committed to develop a comprehensive training program of its own, with full implementation expected prior to December 31, 1987. The inspector reviewed the licensee's progress in this area to date. A job- and procedure-based task analysis was recently completed. The Health Physics / Chemistry training staff sought to determine which procedures were relevant, to discuss them with supervisors and subject matter experts, and to look at duty areas as described in INPO, in order to have a basis for developing the necessary training areas. The Health Physics /

Chemistry training supervisor stated that the next stage of develop-ment (instructional objectives) should be completed close to or on schedule, and that the training program should be functional by July 30, 1987. Full implementation, including participation in training courses by affected personnel, is still expected to be completed prior to December 31, 1987. The licensee has made sub-stantial progress in meeting the commitments made with regard to training of personnel involved with radwaste; this item remains open pending completion of its commitments and subsequent review by the NR .20 (0 pen) Violation (245/86-06-02; 336/86-06-02) Personnel not properly trained: The 11censee's action taken in response to item numbers 245/86-06-01; 336/86-06-01 (see paragraph 2.19) also apply to this item. This item remains open pending completion of the licensee's commitments and subsequent review by the NR .21 (Closed) Violation (245/86-06-03; 336/86-06-03) Licensee did not have copies of drawings and other documents as required: In its response to this item, the licensee committed to the following corrective actions: (a) Obtain copies of all documents and drawings

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utilized in the preparation of radioactive shipments on March 5 and 14, 1986, and (b) revise radwaste procedures 6003/26003/36003 and 6004/26004/36004 to clarify document and drawing retention requirements. The inspector reviewed the packages of documents and drawings for the two referenced shipments, as well as the revised radwaste procedures, arid verified that the licensee had met its commitment .22 (Closed) Violation (245/86-06-04; 336/86-06-04) Licensee failed to conduct a process control program as required by Technical Specification 6.16: A contract vendor performed solidification of radioacti w wastes between March 1985 and March 1986, but the vendor's procedures did not contain all the detailed information required by item 4 of the licensee's Process Control Program (PCP).

The licensee's response to this item included a commitment to review station and vendor procedures, and upgrade them as necessary to ensure that they comply with the Process Control Program require-ments.

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The licensee stated that the only solidifications performed since this item was identified were accomplished by a vendor in November, 1986. The inspector reviewed the vendor's procedures for the soli-dification process with respect to the six commitments in Item 4 of the PCP. Commitment (a) is to provide "a general description of laboratory mixing of a sample of the waste to arrive at process parameters prior to commencing the solidification process." Commit-ment (c) requires "a general description of sampling of at least one representative sample from every tenth batch to ensure solidification and action to be taken if the sample fails to verify solidification."

The vendor's procedure 8827-001, Rev. A, includes the necessary information in sections 9.1 and 9.2 to satisfy commitment (a). The solidifications performed in November 1986 consisted of two batche Prior to beginning the solidification process, the vendor took a sample of each batch and verified that the solidification of the samples occurred as expected. This in effect met the requirement of commitment (c), since only the two batches were solidified. The licensee further stated that a sample would be taken from each batch for all solidifications, regardless of the number to be performe The inspector stated that nevertheless, the vendor's procedures need to be made more specific regarding how commitment (c) would be me The licensee stated that prior to performing any further solidifi-cations, future revisions to station and vendor solidification pro-cedures would more explicitly describe how commitment (c) is me .23 (Closed) Violation (245/86-06-05; 336/86-06-05) QC program was inadequate to assure compliance with 10 CFR 20.311 03: This regulation requires the licensee to conduct a quality control program to ensure compliance with 10 CFR 61.55 and 61.5 In its

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response to this item, the licensee stated that no Corporate or Station procedures were in effect at the time of a March, 1986, solidification which addressed the process control program required by 10 CFR 61.5 Corrective steps taken by the licensee included the implementation of a corporate policy (NE0 6.07) that specifies a quality control program to assure compliance with 10 CFR 61.56. This policy was implemented at Millstone station by incorporating NE0 6.07 into a new procedure, ACP-0A-2.018, which has since been revised to ACP-QA-2.01A, Rev. 4. This procedure, entitled " Radioactive Material and Waste Packaging, Shipping and Processing Quality Assurance Program," specifies how and to what extent the QA program applies to preparation of radioactive waste for shipmen The licensee's response to this item, as in the previous item (para-graph 2.22) included a commitment to review station and vendor pro-cedures involving solidification of radioactive waste, and upgrade them as necessary to ensure compliance with the requirements of NE0 6.07 and ACP-QA-2.018 (now ACP-QA-2.01A). As stated in paragraph 2.22, the inspector reviewed the vendor's procedures for the solidt-fication process with respect to the six commitments in Item 4 of the PCP, and stated that the vendor's procedures need to be made more specific regarding how commitment (c) would be me .24 (0 pen) Inspector followup Item (245/86-11-01; 336/86-11-01) Revise procedure CP-800/2800 to include Fe-55 spike analysis and to empha-size intercomparisons of counting geometries other than liquid: The licensee stated that the vendor QC program now includes split sample analysis for Fe-55, but that preparation of Fe-55 spiked samples has not yet begun. The licensee further stated that it expects to begin this aspect of its QC program in the near futur With regard to QC checks of other counting geometries, the licensee stated that this would be difficult because other licensees parti-cipating in the intercomparison prograa (all located in Region I) do not necessarily utilize the same countiag geometries for analyses of charcoal cartridges, particulate filters, and gases. The licensee stated that a spiked liquid sample could be prepared and then put into any suitable container according to the geometry utilized by a particular licensee, whereas such flexibility is not possible with the other types of samples. The inspector stated that based on NRC experience in inspections of Region I licensees, a ;ufficient number of them use identical counting geometries to allow'intercomparisons of at least some of the geometries used by Millstone station with some of the other licensees pact'cipating in its intercomparison program. The licensee stated that it would discuss this matter with the other participants in the intercomparison progra This item remains open and will be reviewed in a future inspectio ;

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2.25 (Closed) Inspector Followup Item (336/86-11-02) Document validity of computer code used by Unit 2 Chemistry for dose calculations. -The i

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licensee performed hand calculations to verify the results of the computer code, and attached these to a memo to document that the verification had been performed. Although the licensee had agreed at the conclusion of inspection 86-11 to do this documentation, the inspector noted that no progress had been made on this item as of the beginning of this inspection. The licensee completed it after the inspector inquired as to the status of this commitmen .0 Exit Meeting The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 13, 1987. The inspector summarized the status of the items reviewed during the inspec-tion. The inspector provided the licensee with a list of items reviewe No other written material was provided to the licensee by the inspecto .

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ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In these criteria, the judgement limits are variable in relation to the com-parison of the NRC Reference Laboratory's value-to its associated uncertaint As that ratio, referred to in this program as " Resolution", increases, the acceptability of a licensee's measurement should be more selectiv Conversely, poorer agreement must be considered acceptable as the resolution decrease Resolution = NRC REFERENCE VALUE Ratio = LICENSEE VALUE REFERENCE VALUE UNCERTAINTY NRC REFERENCE VALUE Resolution Agreement (Ratio)

<3 0.4 - .5 - .6 -

1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25-

>200 0.85 - 1.18

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o TABLE 1 MILLSTONE UN,i 3 VERIFICATION TEST RESULTS RESULTS IN MICROCURIES PER MILLILITER ANALYSIS BY ISOTOPE NRC VALUE LICENSEE VALUE COMPARISON Unit 3 Cs-137 (8.18 1 0.25) E-6 (8.7 1 0.3) E-6 Ag reement Chem i st ry Co-60 (7.28 1 0.14) E-6 (7.8 1 0.3) E-6 Ag reement Detector 2 Mn-54 (5.05 1 0.10) E-6 (5.6 1 0.3) E-6 Ag reemen t Unit 3 Cs-137 (8.18 1 0.25) E-6 (8.5 1 0.2) E-6 Ag reement Chemistry Co-60 (7.28 1 0.14) E-6 (7.5 i O.3) E-6 Ag reement Detector 3 Mn-54 (5.05 1 0.10) E-6 (5.2 1 0.2) E-6 Ag reement Unit 3 H-3 (8.98 1 0.20) E-4 (2.63 i *) E-3 Disag reement **

Chem i st ry H-3 (8.98 1 0.20) E-4 (2.57 i *) E-3 Disag reement **

V;ndor H-3 (8.98 1 0.20) E-4 (7.8 i *) E-4 Ag reement Lcbo ra to ry S r-89 (1.13 1 0.03) E-3 ( *) E-3 Ag reement S r-90 (1.07 1 0.04) E-4 ( *) E-4 Ag reement Fe-55 (6.66 1 0.13) E-4 ( i *) E-4 D i sag reement **

• Error term not stated by licensee

• o See text, pa rag raph 2.17