ML17319A996

Responds to NRC 810609 Notice of Violation Re Radwaste Shipment.Corrective Actions Provided in Encl Util 810316 Ltr to State of Nv.Consultant Plant Insp of Radwaste Program Initiated.Personnel Retrained Annually

ML17319A996
Person / Time
Site:	Cook
Issue date:	07/24/1981
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
AEP:NRC:00587, AEP:NRC:587, NUDOCS 8107310241
Download: ML17319A996 (13)

Text

INDIANA L'ICHIGAN ELECTRIC COMPANY P. O. BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 July 24, 1981

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)E FII E COI'%I AEP:NRC:00587 kali WC'mm,rOgg CohNISS KN pe Cl Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 RESPONSE TO THE NOTICE OF VIOLATION ON RADIOACTIVE WASTE SHIPMENT Mr. V. Stello, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Stello:

American Electric Power Service Corporation (AEPSC) for itself and for Indiana 8 Michigan Electric Company, (IMECo),owner, operator, and licensee of the Donald C. Cook Nuclear Power Plant, hereby responds to the NOTICE OF VIOLATION, attached as Appendix A to a letter dated June 9, 1981, from Mr. Dudley Thompson, Director-Division of Enforcement and Investigation, as follows:

A. As to the alleged violation in paragraph A, in response to question (1) AEPSC admits that the violation occurred.

In response to questions (2), (3), and (4), attached hereto and made a part hereof as Exhibit A is a copy of a letter from Indiana 8 Michigan Electric Company. to the State of Nevada completely explaining the incident and the corrective steps which have been taken. In response to question (5), full:compliance has been achieved. As Mr. Thompson's June 9 letter states, our Nevada permit was reissued on April 15, 1981.

However, despite this admission of violation, AEPSC does notbelieve it merits classification as a Severity 'III violation nor any further enforcement action by the NRC.

Specifically, we do not believe it justified to include this particular violation in IMECo's license enforcement history in light of the policy on escalated enforcement sanctions as contained in Table 2, 45 Fed. Reg. 66757.

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Mr. V. Stello AEP:NRC:00587 B. As to the alleged violation in paragraph B, in response to question (1) AEPSC does not have sufficient information

- to form an opinion as to whether the alleged violation occurred. Reference is again made to Exhibit A for a complete explanation of this incident. As far as we know, the radioactive waste had been dried before it was shipped.

AEPSC believes that approximately 100 milliliters of liquid were drained from -the 1,000-gallon tank, which represents approximately 0.0026$ of the tank's capacity. Whether the presence of this miniscule amount of moisture resulted in a violation. of the State of Nevada license is not known by us. Nor is it known how the liquid accumulated in the first place since, as Exhibit A states, our final inspection of the tank before shipment revealed no liquid. Indeed, the State of Nevada's letter of February 24, 1981, which. suspended our permit, did,not specifically state that liquid had been found. We thus are not in a position to admit or deny the allegation.'owever, we do believe that the State of Nevada's enforcement action and our response thereto should satisfy NRC's concerns in this matter.

In any event; AEPSC does not believe it merits classification as a Severity Level III violation nor'any further enforcement action by the NRC. Specifically, we do not believe it justified to include this particular violation in IMECo's license enforce-ment history in light of the policy on escalated enforcement sanctions as contained in Table 2, 45 Fed. Reg. 66757.

A two week extension for submitting this response was granted by Mr. Thompson on July 2, 1981.

Very ruly yours, R. S. Hunter Vice President cc: John E. Dolan - Columbus R. C. Callen G. Charnoff R. W. Jurgensen D. V. Shaller - Bridgman Joe Williams, Jr.

D. Thompson - NRC Region III Resident Inspector - Bridgman

STATE OF NEW YORK )

COUNTY OF NEW YORK)

R. S. Hunter, being duly sworn, deposes and says. that'e is the Vice President of Licensee Indiana 8 Michigan Electric Company, that he has read the foregoing response to the Notice of Violation contained in Appendix A to Mr. Dudley Thompson's letter dated June 9, 1981 and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.

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.. IVII.'l.l.I,ll rl. IIl.rlCK I la'Jl Ila'llI March 16, 1981 EXHIBIT A TO .'.AEP:NRC:587 Mr. John Vaden Supervisor, Radiological Health Division oF Health State of Nevada 505 East King Street Carson City, Nevada 89710

Dear Mr. >laden:

This letter is in response to 'your letter of February 24, 1981. You requested information concerning the actions which the Donald C. Cook Nuclear Plant would institute to'revent any recurrence of the problem which.occ<<ried on our last shipment of low level radwaste to the Beatty disposal site. In that letter you outlined four (4) actions which will be necessary in order to have our Permit Number 249 reinstateu.

Before discussing the changes which wI have made as a result of this occurrence, i t vIould be hei pl ul to review the history nf 'tI)e tanks involved.

These tanks were originally purchased to be used in our urea-formaldehyde (UF) soliiliFication system. In 1980 we made a decision to chanqe our

.solidification system from a UF media to cement because of the changing regulatory climate regarding the amount of free stan'ding liquid.

7his change was eFfected in September of 1980, but we fou'nd ourselves with several oF these. UF tanks remaining. In particular, the tank which caused the problem was used as a holding tank For the last of the dewatering liquids from our UF operation. In preparing the tank for

'hipment, the dewatering liquid which it contained was removed. It should. be noted, that some small. leakage was noticed at the "'Qld vIhich held the low point drain in place. The weld was dried anJ cleaned, and then covereJ ivith epoxy to seal it.

The tank was then tilted so that any re'maining liquid vIould drain nut; it was left open to allow it to dry; it was further dried by blowing air into it. Lost.ly, it was inspected by having o mon'physically enter Ihu tank and check specifically for any liquid. That inspection only reported the presence oF moist crystalline boric acid in the bottom of the tank. Having prepared the tank for. shipment it was then FilleJ with bagged dry active waste. Ile believed tl'at the extra precautions taken wert'uff'icient to assure a strong tiqht shippinq cnntointr.

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Page 2 March 16, 198l Mr. John Vaden As described above, the way in which these tanks were used is not typical of the manner, in'hich we ship and dispose of radwaste. From the exper-

'ence which resulted, we have made the following changes to our radwaste procedures:

1. We will'ot use the remaining UF tanks as shipp'ing containers.

They wi)I be cut up and placed in boxes prior to shipment.

2.. Our.procedures have been revised to prohibit the use of any epoxy material on any tank.

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• They have now been mode fied to state speci fic re<luiiements concern-

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ing the inspection oF packages to see that they are visual ly leak ti'ght and have no indicationof weak areas, paying speci.fic attention to iqelds.

4. 'Should this more thorough inspection result in ident ifyinq any leaks or w<<ak areas on any tank or shipl>i>>g p )ckagu, i i wi I I not lie shipped. I t may be e.i ther repacked or placeJ in an

- overpack prior to shipment.

These are the changes which we have niade to our'adwaste program to assure that this incident will not occur again. A discussion of our radwaste program follows:

The plant currently has in place procedures which insure compliance with all current regulations, burial site licenses, and transport permits.

There procedures include:-

PHI 3150 "Receipt, Packaging, and Shipment of Radioactive and Fissile Hateri'a I" PHI 3150 PCP.OOI "Radioactive Waste Process Control Manual" 12 TIIP 6010 RAD.303 "Solid Waste Handling and Drumming" J

12 THP 6010 RAD.304 "Shipment of Radioactive Materials" The above procedures pertain to all=aspects of the packaging and shipping oF compressibles, noncompressibles, res.ins and evaporator bottom radwastes.

These -.procedures also identify the personnel responsible for verification of acceptance crit. ria. Verifications are 'performed using se'veral methods at different, stages oF packaging to insure compliance prior to shipment.

e In addition to these verifications, the. Plant Quail ty Assurance D'epart-ment performs in-depth inspections and audi ts of the ra<iwaste Iwndl ing operation. Fur ther, as'equired by our operat ing I icon~~, the Vi.t icon Electric Power Set vice Corporation m,~intains a Nuclear Safe ty and Design Review Conioittee which performs an annual audit oi the pl uit's r. dioact ive

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waste handl ing op'erations. Further, the plant currently has tulo on-si te NRC Inspectors ~iho periodical ly review radwastc I)andi lh(J ln ad(li ti'on to the annual audit perfornied by the NRC's Inspection and Enforcement Division of Region, I I I. Each of'hese inspe'ctions an~) nut)i ts are intended to )>)en-

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tify any. ii)adequacies which might lead'o possibli regulator y viola) ion Al) plant and contrac't personnel who handle radwaste packaging and shipping are trained in the applicable procedures 'and regulations,.

including the state's requirements and burial si te criteria. This train-ing is given to insure that each phase in the preparat ion of a package for burial is perrormed'by personnel who are.knovledgcable of the require-ments placed on the final package. In;.add,i.tion, the i ant supe'rvisors responsibi'e"for certiffc'ation of radioactive ujaste shif>ni.nts are receiving,'0 CFR an(l >lj CFR.rules changes biinonthly and are requir ed to ~ev'iew them for appl icabi I'i ty to our radwaste program and to documer>t the. results. of each 'review.

Enclosed is a copy of our letter to Nevada Inspection Services,"Inc.

(NIS) to per forn 'z plant inspection of our radwaste'>rogram.'he I)ro'-

cedures described above are also enclosed. It is p'res).nt ly a condit.,ion of our license that approved procedures be estab)')shed, hnplen:ented and maintained. for our raduiaste program. These procedures have been eval-uated by the NRC, have been found to be acceptable, anil are reviewed periodical ly dt ring their audits'. The. changes discussed. above wi ) I fu~'-

ther enhance th<<se'procedures and improve our han<)l ing of i adtvaste. To the best ot'ur knowledge, the NRC wi I I not make these procedures a

• part of our operating license. However, as approved. plant'rocedures, the'y.must be followed under'our operating license. Any non-conipliance involving any approved plant procedure may result in an enforcement

,action by the NRC.

this incident a ~

In summary,

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responsible f'r radwaste packaging, 'nc'luding the procedure changes discussed above. All plant procedures are period,ically reviewed and updated to address changes as required. Personnel are trained and retrained at )east annually. Audits are being. conducted and:packages

.are being'nspected and verified. .Management personnel are keeping abreast of regulations and.assuring co'mpl iance. These' telns ccnnbined with the most recent, changes to our procedures as a result of')iis incident an(I a I'now)edge 'of burial s i te operat ions and cr i teria sl>ould el iminate any further violat ions.

Please be assured) that it is our intent to comjly'ith all applicabl(.

federal, state and local regulations concerning radwacte. It is our "understanding tiia( with the new re<iu)atinns taking <<ffiet Ai~ril I, I'981, it may be several weeks bef'or e NIS can audit ttie plant. In the interini, we would like to meet with you to supply 'any .cl'arifications or details wh I ch you ru(iul"> I

'i Page 4 March 16, l98l Mr. John Vaden Please and Chief you have We contact Mr. R. W. Jurgensen who is an As'sistant Vice President tluclear Engineer of. our Service Corporation with any questions, in regard to this. letter and setting up a meeting. You can reach him at 212/440-9280.

are eager to demonstrate to you that we are a responsibl.u HRC licensee and have to your satisfaction, sufficiently and adequately add~ essed thu causes of the problem which recently occurred.

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Enclosures cc;. R. S. i(unger R. W. Jurgensen D. 'V. Shaller .

Very l l truly yours, iam A. Black President

-0 Page 5 March 16, 1981 Mr. dohn Va<len bcc: =

E. L. Toiinley E. A. Szarre1la/T. A.'rlesel H. L. Sobel G. E. Letlasters