Information Notice No.: 87-07: Quality Control of Onsite Dewatering/Solidification Operations by Outside Contractors
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
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IN 87-07
February 3, 1987
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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.
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IN 87-07
February 3, 1987
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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
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