United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No.: 87-07: Quality Control of Onsite Dewatering/Solidification Operations by Outside Contractors

                                                    SSINS No.: 6835 
                                                            IN 87-07       
                                UNITED STATES
                           WASHINGTON, D. C. 20555

                              February 3, 1987

Information Notice No. NO: 87-07:   QUALITY CONTROL OF ONSITE DEWATERING/ 
                                   SOLIDIFICATION OPERATIONS BY OUTSIDE 


All nuclear power reactor facilities holding an operating license (OL) or 
construction permit (CP). 


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. 


                                                       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 


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

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