ML17056A730

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Responds to Re Radwaste Facility Bldg Being Used as long-term Liquid Waste Retention Facility at Plant.No Violation of Regulatory Requirements Occurred Due to Inadvertent Loss of Records.Insp Rept 50-220/89-80 Encl
ML17056A730
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 03/30/1990
From: Ronald Bellamy
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Resnikoff M
RADIOACTIVE WASTE MANAGEMENT ASSOCIATES
Shared Package
ML17056A731 List:
References
NUDOCS 9004100140
Download: ML17056A730 (8)


See also: IR 05000220/1989080

Text

MAR 8 0 1990

Radioactive

Waste

Management

Associates

ATTN:

Marvin Resnikoff, Ph.D,

Senior Associate

306 West 38th Street,

Room 1508

New York, New York 10018

Dear

Dr. Resnikoff:

I am responding to your letter of March 5, 1990, concerning the Nine Mile Point

Unit I reactor.

In your letter you stated that two aspects

of the incident

where Niagara

Mohawk used the Radwaste

Building sub-basement

as

a long-term

liquid waste retention facility should

be more fully examined

by the Nuclear

Regulatory

Commission.

Further,

you raised several

specific points regarding

the

NRC's regulatory actions.

Below they are addressed.

In your Item

A you correctly point out that the flooding of the radwaste

building sub-basement

ultimately resulted in the need to release

water to Lake

Ontario.

The releases

that were made

by the licensee

were allowed by federal

regulations

and were properly reported to the

NRC.

The releases

were made in

a controlled manner at very low concentrations

thus ensuring protection of

public health

and safety

and protection of the environment.

Your Item A also states

that the total

amount of excess

water released

to the

sub-basement

was 90,000 gallons

and that

NRC may not have

been

aware of this

amount of water.

The Augmented

Inspection

Team (AIT) reviewed all water

released

to the sub-basement

during the inspection

conducted

in August,

1989.

'he water was disposed of by one of two means, either by release

to Lake

Ontario

as described

above,

or by temporary storage

onsite

and subsequent

evaporation.

Residue

from the evaporation

process

was shipped to an authorized

disposal site

as solid radwaste.

Such shipments

were

made in accordance

with

NRC and the Department of Transportation regulations,

thus public health

and

safety

was ensured.

All releases

to the sub-basement

and licensee

notifications were covered in the AIT Report

and in subsequent

enforcement

actions.

In your Item

B you suggested

that, associated

with the

1981 radwaste building

flooding event,

the evaporator

was being directly vented to the environment.

The design of the evaporator

precludes

the presence

of a direct non-filtered

pathway to the environment.

The vapor that is generated

during operation of

the evaporator is condensed

in the vapor condenser.

The distillate is then

cooled

and routed to floor drains which lead back to the radwaste building for

storage,

and further processing

and reuse.

The non-condensables

are routed to

the ventilation system

where they are monitored

and filtered.

All releases

Marvin Resnikoff

MAR 8 0 1990

from the building ventilation system are controlled by federal regulations

and

are reported to the

NRC.

Our review of licensee's

records in this area

indicates that releases

have

been within regulatory limits thus ensuring

protection of public health

and safety

and protection of the environment.

Regarding radioactive

cesium detected

in milk samples

during 1981, this issue

was addressed

in Section 6.0 of the AIT inspection report.

As described

in the

AIT report, it is the conclusion of the inspection

team that the elevated

concentrations

of radioactive

cesium measured

in milk were not a result of

releases

from the facility.

Regarding your comments

in the area of the enforcement action taken

by the

NRC,

these

subjects

were addressed

in NRC's Notice of Violation issued to Niagara

Mohawk on February 23,

1990.

A copy of that action is enclosed.

Please refer

to that document for an explanation of the considerations

that were taken in

arriving at the regulatory conclusions for this event.

With regard to your comment concerning

the records of the barrel contents,

those

records primarily are required for preparation of documentation at the

time of shipment for disposal.

They became

unusable

because of the flooding

of the sub-basement.

The licensee will have to requantify the contents of the

drums

and reconstruct

the records prior to such shipment,

but no violation of

regulatory requirements

occurred

due to the inadvertent

loss of the records.

With regard to your comment that the incident should

have

been reported to the

NRC under

10 CFR 20.403,

the staff carefully considered

this as

a potential

violation. It was concluded that the incident was not required to have

been

reported.

As

a result, there is no basis for concluding that the licensee

was

involved in a "cover-up," as you suggested.

I hope this letter addresses

your concerns

to your satisfaction.

Sincerely,

Encl:

As stated

Ronald

R. Bellamy, Chief

Facilities Radiological Safety

and Safeguards

Branch

Division of Radiation Safety

and Safeguards

cc w/encl:

M. Knapp

R. Pollard

Representative

Louise

M. Slaughter

Public Document

Room

(PDR)

Local Public Document

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(LPDR)

Region I Docket

Room (w/concurrences)

(50-220)

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