Home > NRC Library > Document Collections > General Communications > Information Notices > 1987 > IN 87-07
SSINS No.: 6835 IN 87-07 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C. 20555 February 3, 1987 Information Notice No. NO: 87-07: QUALITY CONTROL OF ONSITE DEWATERING/ SOLIDIFICATION OPERATIONS BY OUTSIDE CONTRACTORS Addressees: All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP). Purpose: This notice is intended to remind licensees of their responsibility to ensure that appropriate quality control measures are carried out during the operation performed by outside contractors of transportable dewatering and/or solidification radwaste processing equipment at the site of a licensed facility. It is suggested that recipients review the information for applicability to their facilities. No written response is required. Related Documents: Information Notice No. 79-09, "Spill of Radioactively Contaminated Resin," March 30, 1979. This notice reminded licensees of their responsibility to review the adequacy of the equipment and procedures used by such outside contractors. NRC IE Circular 80-18, "10 CFR 50.59 Safety Evaluation for Changes to Radioactive Waste Treatment Systems," August 22, 1980. This circular pointed out that in some instances, licensees have failed to perform adequate safety evaluations to support changes to solidification/dewatering systems operated by an outside contractor at a licensee's facility, so as to determine that there are no unresolved safety issues. Background: The functions performed by mobile transportable radwaste processing equipment for solidification or dewatering (e.g., usually skid mounted or truck mounted) are very often performed by outside contractor personnel. Such operations fall within the scope of the operating reactor's license issued pursuant to 10 CFR 50. Therefore, regardless of the specific method of processing the waste or the contractor involved, the licensee is responsible for ensuring that all such activities on his site are carried out in a manner consistent with the facility operating license and applicable technical specifications, process control program and regulations, in a manner that provides adequate protection from the health, safety, and environmental standpoints. 8701300079 . IN 87-07 February 3, 1987 Page 2 of 3 A very important and somewhat recent regulatory requirement relating to such operations is found in 10 CFR 20.311(d)(3), which requires that a licensee shall " ....conduct a quality control program to assure compliance with **61.55 and 61.56 of this chapter; the program must include management evaluation of audits." Description of Circumstances: Several recent NRC inspections have revealed inadequacies in quality control programs during such operations. A typical result of these inadequacies is the failure to reduce the water content of solidified wastes or dewatered resins to the applicable limits; for example, either 0.5% by volume of the stable waste form or 1% by volume of the waste when placed in a disposal container, a "High Integrity Container" which is designed to ensure stability. This has resulted in enforcement actions and/or civil penalties against the shipper/licensee by the burial site state licensing authority. In some instances, it has been observed that no quality control program is in place by either the contractor or the licensee. Typically, the contractor might perform the solidification/ dewatering without any holdpoints or quality control check points by either the licensee or the contractor, especially a control check that is independent of the operator of the waste processing equipment. It has also been found that in some cases, quality assurance audits have neither been performed nor have the results of such audits, when performed by contractor personnel, been reviewed by licensee management. Discussion: The operations conducted at a licensee facility by an outside vendor are usually addressed in the licensee's process control program, which is an incorporated requirement of the applicable Technical Specification. It is incumbent on the licensee to exercise oversight and control of all aspects of the contractor's operation. This includes review of sample results, test solidification results, product verifications, and quality control audits. Licensee controls must be adequate to ensure compliance with the requirements of 10 CFR 20.311 and 10 CFR 61.56. It is expected that licensees will review the information provided for applicability, if appropriate, to their waste management programs. However, suggestions contained in this notice do not constitute NRC requirements; therefore, no specific action or written response is required. . IN 87-07 February 3, 1987 Page 3 of 3 If you have questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office. Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical Contact: A. W. Grella, IE (301) 492-7746 Attachment: List of Recently Issued IE Information Notices .
Page Last Reviewed/Updated Thursday, March 29, 2012